Case Digest (G.R. No. L-44001) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Marcos R. Esmaquel and Victoria Sordevilla vs. Maria Coprada (G.R. No. 152423, December 15, 2010), petitioners Esmaquel and Sordevilla filed an ejectment case on February 24, 1997 before the 2nd Municipal Circuit Trial Court of Magdalena, Liliw and Majayjay, Laguna. They asserted they held Torrens title (TCT No. T-93542) over a 253-square-meter lot in Majayjay, Laguna, which respondent Coprada had occupied since 1945 with permission but without paying rent or taxes. Petitioners, moved by pity, refrained from ousting her despite improved circumstances, and only in August 1996 formally demanded her to vacate. After Coprada ignored a barangay conciliation effort and the demand letter, petitioners filed ejectment. Coprada admitted the registered title but claimed an oral sale of 100 sqm in 1962 and alleged laches on petitioners’ part or, alternatively, that she was a builder in good faith entitled to reimbursement under Articles 546 and 548 of the Civil Code. The MCTC dis Case Digest (G.R. No. L-44001) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Ownership and Initial Occupation
- Petitioners Marcos R. Esmaquel and Victoria Sordevilla are the registered owners of a 253‐sqm parcel in Barangay San Miguel, Majayjay, Laguna, covered by Transfer Certificate of Title No. T-93542.
- In 1945, out of pity, petitioners allowed respondent Maria Coprada and her family to occupy the land rent-free, upon condition they vacate when needed; respondent built a nipa hut, later a semi-concrete house, and began paying real property taxes in 1984 (in petitioners’ names).
- Respondent’s Alleged Acquisition and Defense
- Respondent contends permission originated from Emiliana Coprada (Victoria’s mother) in 1945, as the lot was then wasteland.
- She claims an oral agreement with Victoria in the early 1960s to buy a 100-sqm portion for ₱2,000, paid in installments by 1962; no written deed or receipt was executed.
- Respondent asserts payment of taxes and improvements qualify her as a builder in good faith, entitled to reimbursement or retention under Articles 448, 546, and 548 of the Civil Code.
- She further maintains petitioners’ delay in asserting their rights constitutes laches barring ejectment.
- Demand and Course of Proceedings
- Petitioners made a verbal demand, then a letter dated August 22, 1996 giving respondent until November 30, 1996 to vacate; barangay mediation failed.
- On February 24, 1997, petitioners filed an ejectment complaint in the 2nd Municipal Circuit Trial Court (MCTC) of Magdalena, Liliw and Majayjay, Laguna.
- MCTC Decision (September 11, 1997): dismissed complaint, ruling laches barred petitioners and presuming valid oral sale.
- RTC Decision (November 24, 1998): reversed MCTC, found respondent’s possession unlawful upon demand, ordered ejectment and removal of improvements.
- CA Decision (April 6, 2001) and Resolution (February 15, 2002): reinstated MCTC dismissal; SC granted petition for certiorari under Rule 45.
Issues:
- Whether the registered owners’ right to recover possession under a Torrens title is imprescriptible and immune from laches.
- Whether respondent’s unproven oral sale claim can defeat petitioners’ ownership and right to eject.
- Whether laches had set in against petitioners or respondent.
- Whether petitioners’ Torrens certificate of title may be collaterally attacked in an ejectment case.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)