G.R. No. 184535 - Versoza vs. People

Spouses Efren G. GoAo and Rafaelita R. GoAo (hereafter, spouses GoAo) own and operate Villa Alexandra Beach Resort and Restaurant in Barangay Matabungkay, Lian, Batangas.
Spouses Pablo Calimlim and Patnubay Isla Calimlim (hereafter, spouses Calimlim), replaced by Bienvenido Calimlim and Rufina Cabral, operate informal structures including rest houses, video machines, videoke sets, billiard tables, sari-sari stores, and carinderias along Matabungkay Beach shore.

On January 3, 2012, spouses GoAo filed a complaint for abatement of nuisance, easement, and injunction against spouses Calimlim.
Spouses GoAo alleged spouses Calimlim's structures caused discomfort to their guests, obstructed the view of their resort, and were illegally erected on foreshore land declared a tourist and maritime reserve zone.
Spouses Calimlim allegedly operated without necessary permits and did not pay taxes or issue official receipts.
Spouses Calimlim's activities produced excessive noise, offensive odors, and environmental contamination (e.g., water seepage from toilets).
They maintained open-fire kitchens posing fire hazards, including one fire incident allegedly resulting from their electrical line.
Spouses GoAo demanded removal of structures and resorted to barangay-level complaint and government agencies without success.
Spouses GoAo claimed actual damages and prayed for demolition, cease-and-desist orders, easement rights, and damages.

Spouses Calimlim claimed they had occupied the land for over 50 years prior to Villa Alexandra.
They argued that competition caused spouses GoAo's income loss, not their activities.
They denied obstruction or nuisance and filed a counterclaim for moral and exemplary damages.

Spouses GoAo's request for a temporary restraining order was initially denied for lack of affidavit of merit.
Attempts at mediation failed; substitution of parties was allowed for deceased spouses Calimlim.
Parties stipulated certain facts including lack of land title by spouses Calimlim and denial of foreshore lease application.
Spouses Calimlim failed to present evidence despite opportunities; trial court deemed them to have waived the right.
Trial court dismissed spouses GoAo's complaint, holding no proof of intentional or negligent nuisance and that income loss was due to market competition.

On appeal, spouses GoAo argued illegal occupancy, bad faith, public nuisance, and entitlement to damages.
Spouses Calimlim claimed violation of the Judicial Affidavit Rule by spouses GoAo.
Court of Appeals admitted spouses GoAo’s evidence, finding proper authentication and identification.
It reversed trial court judgment, ruled the structures constituted a public nuisance, ordered demolition and vacation of premises, awarded temperate, moral, exemplary damages, and attorney's fees.

Spouses Calimlim invoked violations of the Judicial Affidavit Rule and argued the nuisance should be private, not public.
Spouses GoAo defended the Court of Appeals' ruling, underscoring illegal occupancy, lack of permits, and damage caused.

Whether there was a violation of the Judicial Affidavit Rule that warrants exclusion of spouses GoAo's documentary evidence.
Whether the illegal structures and business operations of spouses Calimlim constitute a nuisance, and if so, whether it is a public or private nuisance.
Whether spouses Calimlim are liable for damages and required to demolish their illegal structures.