Case Digest (G.R. No. 251537)
Facts:
Spouses Teofanes and Feliciana Ansok and Spouses Clarito and Jisely Amahit v. Dionesia Tingas, G.R. No. 251537 [Formerly UDK-16573], November 25, 2020, Supreme Court Third Division, Inting, J., writing for the Court.Petitioners are Spouses Teofanes and Feliciana Ansok and Spouses Clarito and Jisely (Jeseli) Amahit; respondent is Dionesia Tingas. The controversy concerns Lot No. 859 in Brgy. Mayabon, Zamboanguita, Negros Oriental, covered by Original Certificate of Title No. OCT-12607 registered in respondent’s name after the Department of Agrarian Reform (DAR) issued CLOA No. 00234689 to respondent.
Initially respondent and the petitioners disputed possession. Petitioners claimed inherited ownership and uninterrupted possession of about 75 years; respondent and her predecessors contended that petitioners occupied by tolerance and must vacate on demand. In September 2004 respondent and predecessors demanded possession; petitioners refused. Respondent and predecessors then filed an unlawful detainer (ejectment) case against petitioners before the 5th Municipal Circuit Trial Court (MCTC) of Zamboanguita–Dauin, docketed as Civil Case No. CC-284. The MCTC ruled for petitioners, finding they had superior right of possession; on appeal the Regional Trial Court (RTC), Branch 40, dismissed the complaint for lack of jurisdiction because the unlawful detainer complaint allegedly lacked essential allegations.
Years later DAR granted respondent a CLOA and she secured OCT No. OCT-12607. Armed with that title, respondent filed a separate Complaint for Recovery of Property and Actual Damages (accion reivindicatoria) against petitioners in the same MCTC, docketed Civil Case No. 2010-338. Petitioners answered asserting res judicata based on the earlier ejectment case, challenged the CLOA/OCT as void, and alleged longstanding possession; they also raised a counterclaim attacking respondent’s title.
On February 14, 2013 the 5th MCTC ruled for respondent, holding that a registered Torrens title gives respondent preferred possessory right and that petitioners’ attack on the title amounted to a collateral attack and was impermissible. Petitioners appealed to RTC Branch 38, Dumaguete City; on July 24, 2013 the RTC affirmed the MCTC decision. Petitioners then elevated the case to the Court of Appeals (CA) in CA-G.R. SP No. 07886; the CA, in a Decision dated March 15, 2018 (pened by Associate Justice Gabriel T. Robeniol, with Associate Justices Gabriel T. Ingles and Marilyn B. Lagura‑Yap concurring), affirmed the RTC on jurisdiction, res judicata, and the impermissibility of collateral attack on OCT. The CA denied petitioners’ motion for reconsideration by Resolution dated Sept...(Pro-only)
Issues:
- Did the Municipal Circuit Trial Court have jurisdiction over respondent’s Complaint for Recovery of Possession and Damages?
- Does respondent hold a better right to possession of Lot No. 859 by virtue of OCT No. OCT-12607?
- Did petitioners’ counterclaim challenging respondent’s Torrens title constitute an impermi...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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