G.R. No. 112172 - Public Estates Authority vs. Court of Appeals

Lot No. 5155 was originally part of a salvage zone and under water until reclaimed by the Public Estates Authority (PEA) in November 1982.
The PEA, being a government agency, asserted its authority over the land, which was later involved in a major infrastructure project—the R-1 Toll Expressway, part of the Manila-Cavite Coastal Road Reclamation Project.

In 1989, the PEA constructed its field office within Lot No. 5155 during the preparation for the coastal road project.
PEA personnel, including project manager Ricardo PeAa and project engineer Ramon Aurellano, Jr., were actively involved in monitoring and intervening in activities on the lot.
On December 27, 1992, Ricardo PeAa ordered PEA security guards to stop further construction activities by the respondent on the lot.

Bernardo de Leon claimed that his father, Faustino P. de Leon, possessed Lot No. 5155 for at least fifty (50) years, a possession uninterrupted by any dispute.
After his father’s death in 1984, de Leon and his siblings maintained possession by continuing to fence and improve the property.
Specific acts of construction included:

December 22, 1992 – Start of construction of two bunkhouses and partial fencing by de Leon.
Early December 1992 – Encounter with PEA personnel wherein de Leon allegedly stated he had management “blessings.”
Completion of additional structures and defenses, including concrete posts and barbed wire fencing, in early January 1993.

January 10, 1993 – After receiving a notice from PEA’s security (MASADA), de Leon tried to justify his possession by presenting documentary evidence of his familial claim.
January 14, 1993 – While de Leon was attending a hearing elsewhere, approximately twenty armed security guards entered Lot No. 5155 and demolished the bunkhouses and fence.
January 15, 1993 – De Leon filed a complaint for damages coupled with a prayer for a writ of preliminary injunction to protect his possession.
January 18, 1993 – The Regional Trial Court of Makati (Branch 135) issued a temporary restraining order to maintain the status quo, prohibiting further disturbance or demolition.
February 8, 1993 – Following a hearing, the court issued an order enjoining the defendants from disturbing the said possession pending further proceedings.
March 1993 – The PEA and its representatives filed a petition for certiorari with a restraining order with the Court of Appeals.
September 30, 1993 – The Court of Appeals dismissed the petition, thereby sustaining the trial court’s injunction.

The central point of contention is whether de Leon and his siblings acquired a lawful title to Lot No. 5155 through their long, continuous, open, exclusive, and notorious possession, allegedly lasting for at least fifty years.
The case involves conflicting claims where one party (PEA) asserts government authority over a public land subject to infrastructure projects, whereas the respondent relies on adverse possession claims.

Whether possession, purportedly lasting for fifty (50) years under a bona fide claim, automatically confers absolute title over a parcel of public land.
Whether the respondent’s alleged continuous possession, commencing with his father’s occupancy and maintained by de Leon and his siblings, suffices to establish ownership.

Whether the principles of adverse possession, traditionally applicable to private lands, can be extended to public lands without any formal grant or reclassification by the government.
If the mere possession in open, continuous, exclusive, and notorious manner is adequate under existing laws and judicial precedents for acquiring title over public domain lands.

Whether the respondent complied with the statutory requisites under the Public Land Act (and its subsequent amendments and related statutes) for judicial confirmation of title.
The adequacy of the respondent’s evidence demonstrating title in fee simple, given that practically all public lands require a clear government grant as a prerequisite for establishing private ownership.

Whether the requisites for granting a preliminary injunction—namely, the existence of a legally protected right and the presence of facts indicating irreparable injury—were met given the nebulous nature of the respondent’s claim.