Case Digest (G.R. No. 195834)
Facts:
In G.R. No. 195834, decided by the Supreme Court on November 9, 2016 under the 1987 Constitution, petitioners Guillermo Salvador et al. sought injunctive relief and quieting of title over a parcel along Juan Luna Street, Gagalangin, Tondo, Manila. They alleged open and notorious occupation for more than thirty years and construction of improvements in good faith on land initially claimed by Patricia, Inc. (TCT No. 35727) but later proved to belong to the City of Manila (TCT No. 44247). A preliminary injunction was granted by the Regional Trial Court (RTC), Branch 32, Manila, which, guided by the majority report of three court-appointed geodetic-engineer commissioners, permanently enjoined Patricia, Inc., from evicting petitioners and collecting rentals. On appeal, the Court of Appeals (CA) in CA-G.R. CV No. 86735 reversed and dismissed the complaint for lack of jurisdiction over the special civil action to quiet title, and lifted the injunction. Petitioners’ motion for reconsideCase Digest (G.R. No. 195834)
Facts:
- Parties and Subject Property
- Petitioners: Guillermo Salvador, Remedios Castro (represented by Paz “Chit” Castro), Leonila Guevarra, Felipe Mariano, Ricardo de Guzman, Virgilio Jimenez (represented by Josie Jimenez), Asuncion Juamiz, Rolando Batang, Carmencita Samson, Augusto Tortosa (represented by Fernando Tortosa), Susana Morante, Luzviminda Bularan, Luz Orozco, Jose Sapico, Leonardo Palad, Abel Baking (represented by Abelina Baking), Graciano Arnaldo (represented by Ludy Arnaldo), Judith Hidalgo, Igmidio Justiniano, Ciriaco Mijares (represented by Fredezwinda Mijares), Jennifer Morante, Teresita Diala, and Anita P. Salar—all occupants and improvers of properties along Juan Luna Street, Gagalangin, Tondo, Manila.
- Respondent: Patricia, Inc., holder of Transfer Certificate of Title (TCT) No. 35727.
- Intervenors-Appellees: City of Manila (holder of TCT No. 44247) and Ciriaco C. Mijares.
- Procedural History
- Petitioners filed in RTC, Branch 32, Manila, a complaint for:
- Preliminary and permanent injunction preventing Patricia, Inc. from evicting them or collecting rentals.
- Quieting of title and removal of cloud over their possessory interests, alleging long possession, improvements in good faith, and that Patricia’s TCT was invalid over prior conveyances.
- Amended complaint added multiple Metropolitan Trial Courts; City of Manila and Mijares filed complaints‐in‐intervention.
- Preliminary injunction was granted. Parties stipulated authenticity of:
- TCT No. 44247 (City of Manila)
- TCT No. 35727 (Patricia, Inc.)
- Approved Plan PSD-38540 and Subdivision Plan PCS-3290.
- RTC appointed three geodetic engineers as commissioners to resolve boundary dispute; majority found land belonged to City of Manila.
- RTC Decision (May 30, 2005): granted permanent injunction enjoining Patricia, Inc. from ejectment and rent collection; awarded attorneys’ fees.
- CA Decision (June 25, 2010; Res. Feb. 16, 2011): reversed and set aside RTC, dismissed complaint for lack of jurisdiction, lack of interest, improper boundary adjudication, and lifted injunction.
- Petitioners appealed to the Supreme Court.
Issues:
- Jurisdiction
- Whether the RTC had jurisdiction over the quieting‐of‐title action absent any allegation of the property’s assessed value.
- Joinder of Causes of Action
- Whether petitioners lawfully joined an ordinary action for injunction with a special civil action for quieting of title.
- Real Party in Interest
- Whether petitioners possessed the requisite legal or equitable interest to maintain both causes of action.
- Injunctive Relief
- Whether petitioners met the requirements for preliminary and permanent injunction in a realty case.
- Boundary Dispute and Section 5, Rule 10
- Whether petitioners could amend their complaint to raise a boundary dispute under Section 5, Rule 10, R. Civ. P.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)