G.R. No. 110115 - Tigno vs. Court of Appeals

The case involves a property dispute over Lot No. 859 in Brgy. Mayabon, Zamboanguita, Negros Oriental, which is covered by Original Certificate of Title (OCT) No. OCT-12607 registered in the name of Dionesia Tingas (respondent).
Conflicting claims arose as petitioners (Spouses Teofanes and Feliciana Ansok; Spouses Clarito and Jisely Amahit) asserted inheritance and continuous possession for 75 years, while the respondent maintained her right as one of the heirs of Cipriana Elma, the former owner.

Initially, both parties had a conflicting understanding regarding the ownership of the property. Petitioners claimed inheritance from Cristina Ansok and Gaudencio Elma, whereas the respondent contended that petitioners occupied the property only by tolerance.
In September 2004, after the respondent and her predecessors demanded that petitioners vacate the property, petitioners refused, relying on their long and uninterrupted possession.

An unlawful detainer case (Civil Case No. CC-284) was filed by the respondent against petitioners before the 5th Municipal Circuit Trial Court (MCTC) of Zamboanguita-Dauin, which ruled in favor of petitioners by concluding that the respondent and other heirs failed to establish that the possession was by mere tolerance.
The dispute was further elevated when the respondent, having obtained a Certificate of Land Ownership Award (CLOA No. 00234689) from the DAR and securing OCT No. OCT-12607, filed a complaint for recovery of property and actual damages (Civil Case No. 2010-338) before the same 5th MCTC, asserting her ownership based on the title.
In subsequent proceedings, the RTC (Regional Trial Court, Branch 38, Dumaguete City) reversed petitioners’ favorable stance in the unlawful detainer case, ruling in favor of the respondent on February 14, 2013, by prioritizing the title (OCT) as the basis of rightful possession.
The petitioners then appealed the RTC decision, but the CA (Court of Appeals) affirmed the RTC ruling, concluding that:

The complaint was not agrarian in nature and properly fell under the jurisdiction of the MCTC;
There was no sufficient basis for res judicata from the earlier unlawful detainer case; and
The petitioners’ counterclaims amounted to an impermissible collateral attack on the respondent’s title.

Petitioners elevated the case to the Supreme Court through a Petition for Review on Certiorari under Rule 45, contesting:

The jurisdiction of the 5th MCTC over the complaint;
The respondent’s better right to possession; and
The classification of their counterclaim as a direct rather than a collateral attack.

The petition sought reversal of the CA’s Decision dated March 15, 2018 and Resolution dated September 20, 2019.

Whether the 5th Municipal Circuit Trial Court (MCTC) had proper jurisdiction over the respondent’s complaint for recovery of possession and consequential damages.
Whether the complaint, being a case for recovery of property and not an agrarian dispute, fell outside the ambit of the DAR’s exclusive jurisdiction.

Whether the respondent possesses a better right to the subject property by virtue of holding the OCT, despite petitioners’ claim of long, uninterrupted, and uncontested possession over 75 years.
Whether the clear-cut title derived from the CLOA and subsequently the OCT outweighs petitioners’ claim of adverse possession.

Whether petitioners’ counterclaim challenging the validity of the respondent’s title constitutes a permissible direct attack on the title.
Whether such counterclaim amounts to an impermissible collateral attack in view of the principle of the indefeasibility of Torrens titles as provided in PD No. 1529, Section 48.