Case Digest (G.R. No. 178411)
Facts:
In Office of the City Mayor of Parañaque City v. Ebio, petitioners comprise several offices of the Parañaque City government and barangay officials of Vitalez, Parañaque City, seeking to construct an eight-meter-wide access road across a 406-square-meter parcel owned by respondents Mario D. Ebio and his children/heirs. Respondents trace ownership to their great-grandfather Jose Vitalez, who gave the land to his son Pedro Vitalez in 1930. Pedro secured a tax declaration in 1966 and paid taxes continuously; respondents’ patriarch, Mario Ebio, married Pedro’s daughter in 1961, built a house with municipal permits in 1964 and 1971, and received a transfer of rights from Pedro in 1987, leading to new tax declarations in his name. In 1999, the barangay enacted a resolution for an access road traversing the land, prompting respondents’ opposition and suspension of works. In 2003, city and barangay officials cut respondents’ trees; subsequent letters to local authorities went unansweredCase Digest (G.R. No. 178411)
Facts:
- Parties and Proceedings
- Petitioners: Various offices of Parañaque City government, Barangay Vitalez officials, and residents.
- Respondents: Mario D. Ebio and his children/heirs claiming ownership of a 406 m² parcel in Vitalez Compound, Parañaque City.
- Origin and Title History of the Land
- Land formed by accretion along Cut-cut Creek; originally occupied by Jose Vitalez, then by his son Pedro Vitalez from 1930.
- Pedro’s affidavit of possession (1966) led to Tax Declaration in his name; real property taxes paid continuously.
- Mario Ebio (Pedro’s son-in-law) built a house on the lot (building permits in 1964, 1971).
- Transfer of Rights by Pedro to Mario (1987); tax declarations reissued in Mario’s name.
- Respondents applied for a sales patent before DENR (pending as of 2005).
- Road Project and Pre-litigation Events
- Barangay Resolution No. 08-1999 sought an 8 m × 60 m access road traversing respondents’ lot; respondents opposed and temporarily halted project.
- In January 2003 city officials cut eight coconut trees on the lot; respondents filed complaints with various agencies.
- Series of barangay and city planning meetings (2003) yielded no agreement; city ordered respondents to vacate (March 2005).
- Judicial Proceedings
- Respondents filed a petition for preliminary injunction in RTC Parañaque (April 2005).
- RTC denied injunction for lack of proven proprietary right, absence of suit for confirmation of title, pending sales patent, and failure to implead the State.
- Court of Appeals reversed (January 31, 2007), applying extraordinary prescription over accreted land and recognizing continuous possession since 1930.
- CA denied reconsideration (June 8, 2007); petitioners filed Rule 45 petition to the Supreme Court.
Issues:
- Procedural Issue
- Whether the State is an indispensable party for an injunction action involving accreted land of a public-domain creek.
- Substantive Issue
- Whether respondents’ character of possession and occupation entitles them to a prohibitory injunction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)