Case Digest (G.R. No. 246826) Core Legal Reasoning Model
Facts:
The case involves Moldex Realty, Inc. and Rey Ignacio Diaz (collectively referred to as Moldex) versus Spouses Ernesto V. Yu and Elsie Ong Yu (Spouses Yu). A Petition for Review on Certiorari was filed on July 28, 2021, challenging the Decision dated November 6, 2018, and the Resolution dated March 19, 2019, issued by the Court of Appeals (CA) in CA-G.R. CV No. 108831. The events leading to the petition stem from a lawsuit initiated by Spouses Yu, owners of two adjacent parcels of land in Dasmarinas, Cavite, under Transfer Certificate of Title No. T-280169 for Lot No. 3869-N-1-A and TCT No. T-280170 for Lot No. 3869-N-1-B. The properties measure 4,061 square meters and 4,062 square meters, respectively. Moldex owned a neighboring property, Lot No. 3870 (TCT No. T-317603), with a total area of 201,246 square meters.
The dispute arose when Spouses Yu alleged that Moldex encroached upon a 3,159-square meter section of their property by constructing a perimeter fence. Despite reque
... Case Digest (G.R. No. 246826) Expanded Legal Reasoning Model
Facts:
- Parties and Property Background
- Petitioners: Moldex Realty, Inc. and Rey Ignacio Diaz.
- Respondents: Spouses Ernesto V. Yu and Elsie Ong Yu.
- Property Details:
- Spouses Yu own two adjoining parcels registered under TCT Nos. T-280169 (Lot 3869-N-1-A, 4,061 sq.m.) and T-280170 (Lot 3869-N-1-B, 4,062 sq.m.), located in Barrio Pala-pala, Dasmarinas, Cavite.
- Moldex is the registered owner of an adjacent 201,246 sq.m. lot (Lot No. 3870 under TCT No. T-317603).
- Both properties originally formed part of the Imus Friar Estate.
- Nature of the Dispute
- Spouses Yu filed an action for a prohibitory injunction seeking to restrain and remove a perimeter fence constructed by Moldex, alleging that the fence encroached upon a 3,159-sq.m. portion of their Lot 3869-N-1-A.
- Despite repeated demands to cease construction and vacate the disputed area, Moldex continued its construction.
- Moldex defended itself by contending that:
- The construction of the perimeter fence was entirely on its own property, as evidenced by its Torrens title.
- The conflict arose from discrepancies between the technical description on the Yu titles and the actual ground location.
- Procedural History and Joint Motion
- In 1995, both parties filed a Joint Motion requesting the trial court to direct the DENR’s Office of the Regional Technical Director, Land Management Bureau, Region IV-A to conduct an on‑site relocation survey for the parcels covered by the Yu property titles.
- Engr. Danilo A. Arellano of the DENR conducted an ocular inspection and relocation survey in the presence of the parties’ representatives and the court clerk.
- Subsequent to the survey, both parties moved for summary judgment, leading to the RTC’s ruling in 1999 dismissing Spouses Yu’s complaint for lack of merit.
- Conflicting Court Rulings
- Regional Trial Court (RTC):
- In its December 27, 1999 decision, the RTC ruled there was no encroachment based on the technical descriptions from the parties’ respective Torrens titles.
- In a later Decision dated July 26, 2016, the RTC again dismissed the complaint, awarded Moldex attorney’s fees, and reiterated that Moldex’s perimeter fence was constructed within the boundaries stated in its title.
- Court of Appeals (CA):
- In its October 15, 2002 decision, the CA reversed the RTC ruling, highlighting discrepancies in the technical descriptions of the titles and remanding the case for further proceedings.
- Eventually, the CA reversed and set aside the RTC decision, ordering:
- Moldex to remove any constructions on the disputed area.
- Moldex’s Motion for Reconsideration was denied in the CA Resolution dated March 19, 2019.
- Petition for Review
- Dissatisfied with the CA ruling, Moldex elevated the issue via a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- Moldex challenged:
- The issuance of the injunction ordering removal of the fence and the associated awards to Spouses Yu.
- The application of issues raised for the first time on appeal, including allegations of collateral attack on its Torrens title and the improper consideration of survey evidence.
Issues:
- Whether the Court of Appeals committed a reversible error in:
- Ordering Moldex to remove the constructed perimeter fence allegedly encroaching on the Yu property.
- Awarding Spouses Yu moral damages and attorney’s fees based on a finding of encroachment.
- Whether the technical descriptions enshrined in the Torrens titles should govern the determination of boundaries despite discrepancies between the titles and the actual ground positions.
- Whether the injunctive relief granted to Spouses Yu constitutes a collateral attack on Moldex’s Torrens title, which is barred by law.
- The proper remedy for a boundary dispute involving errors in technical descriptions – i.e., whether such disputes should be addressed through direct actions aimed at correcting titles rather than through an injunction proceeding.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)