Case Digest (G.R. No. 211845) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Pen Development Corporation and Las Brisas Resort Corporation v. Martinez Leyba, Inc., the petitioner corporations (which subsequently merged into Las Brisas) acquired a parcel under TCT No. 153101 in Antipolo, Rizal, adjacent to three contiguous lots (Lots 29, 30, 31) registered to respondent Martinez Leyba, Inc. under TCT Nos. 250242, 250244 and 250243. In 1967 Las Brisas fenced and occupied its parcel, but surveys in 1968 and again in 1996 (Verification Survey Plan Vs-04-000394 approved by the DENR) revealed that some of its improvements overlapped respondent’s titled lots, covering 567 m² of Lot 29, 1,389 m² of Lot 30 and 1,498 m² of Lot 31. Between 1968 and 1971 respondent sent seven letters demanding cessation of the encroachment, but Las Brisas ignored them and continued constructing a riprapping, an old building and, later, a multi-story complex. Respondent filed a complaint for quieting of title, cancellation of title and recovery of ownership with damages in March 1 Case Digest (G.R. No. 211845) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Titles
- Plaintiff-Appellee Martinez Leyba, Inc. (MLI) is the registered owner of three contiguous parcels in Antipolo, Rizal (Lots 29, 30, 31, Block 3, Pcs-7305) under TCT Nos. 250242, 250243, 250244.
- Defendants-Appellants Pen Development Corporation and Las Brisas Resorts Corporation (which later merged under the name Las Brisas) hold TCT No. 153101 over an adjacent parcel.
- Encroachment and Notices
- In 1967–1968, Las Brisas erected a fence and began developing its lot; surveyors engaged by MLI confirmed overlap onto MLI’s titled land.
- MLI sent letters on 11 March 1968, 31 March 1970, 3 November 1970 and subsequent dates notifying Las Brisas of encroachment and demanding cessation; Las Brisas ignored or disputed the claims and continued construction.
- Verification Survey and Case Filing
- On 23 May 1996, the DENR Regional Technical Director approved Verification Survey Plan VS-04-000394, showing Las Brisas occupied 567 m² of Lot 29, 1,389 m² of Lot 30 and 1,498 m² of Lot 31 under MLI’s TCTs.
- On 24 March 1997, MLI filed a Complaint for Quieting of Title, Cancellation of Title and Recovery of Ownership with Damages against Las Brisas before the RTC of Antipolo (Civil Case No. 97-4386). Las Brisas denied encroachment, asserted valid title and good-faith purchase.
- RTC and CA Proceedings
- RTC Decision (20 January 2009): confirmed overlap; declared Las Brisas a builder in bad faith; ordered cancellation of overlapped portions of TCT 153101; directed turn-over of possession; awarded moral (₱1,000,000), exemplary (₱1,000,000) damages and attorney’s fees (₱100,000).
- CA Decision (17 July 2013): affirmed with modification—deleted moral and exemplary damages, awarded nominal damages of ₱100,000; otherwise affirmed bad-faith finding and cancellation orders. CA Resolution (28 March 2014) denied reconsideration.
Issues:
- Overlapping and Quieting of Title
- Whether TCT No. 153101 overlaps MLI’s TCT Nos. 250242–250244 and casts a cloud requiring cancellation of overlapped portions.
- Whether MLI is entitled to quiet title and recovery of possession of the overlapped areas.
- Good Faith vs. Bad Faith
- Whether Las Brisas is a possessor or builder in bad faith after receipt of MLI’s notices.
- Whether Las Brisas, as builder in good faith, is entitled to indemnity or reimbursement for improvements.
- Procedural Defenses
- Whether MLI’s nearly 30-year delay amounts to laches barring its action.
- Whether hearsay objections to survey plans may be raised for the first time on appeal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)