Title
Spouses Tabino vs. Tabino
Case
G.R. No. 196219
Decision Date
Jul 30, 2014
A dispute over the possession of a lot in Makati City leads to a Supreme Court ruling emphasizing the need to await the outcome of administrative proceedings before taking action in a legal dispute over property ownership.
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Case Digest (G.R. No. 196219)

Facts:

  • The dispute involves a 353-square meter lot in Pembo, Makati City.
  • Parties: Spouses Mauricio M. Tabino and Leonila dela Cruz-Tabino (petitioners) vs. Lazaro M. Tabino (respondent).
  • Both parties occupied the lot in 1985; Mauricio lived on the lot, while Lazaro lived in Novaliches, Quezon City.
  • The lot was subdivided into Lot 2 (184 square meters) for Mauricio and Lot 3 (169 square meters) for Lazaro.
  • Lazaro received a revocable permit to occupy 150 square meters of Lot 3.
  • In 1988, the Bureau of Lands awarded Lot 3 to Lazaro.
  • In 2004, Lazaro filed an ejectment case against Mauricio and Leonila, claiming sole ownership and alleging Mauricio's occupation was tolerated.
  • The Metropolitan Trial Court (MeTC) dismissed Lazaro's complaint, recognizing Mauricio as the bona fide resident of Lot 2.
  • The Regional Trial Court (RTC) upheld the MeTC's decision.
  • The Court of Appeals (CA) reversed the decisions, ordering the petitioners to vacate based on Mauricio's affidavit acknowledging Lazaro's ownership.
  • The petitioners elevated the case to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court partially granted the petition.
  • It reversed and set aside the CA's directive for the petitioners to vacate the premises.
  • The ejectment case proceedings were o...(Unlock)

Ratio:

  • The appellate court erred in ordering the petitioners to vacate due to pending DENR Protests.
  • The DENR's findings, favoring the petitioners as bona fide residents, should be respected and final.
  • Proceeding with the ejectment case without awaiting the DENR Protests' outcome could lead to unjust and irreversible consequences, such as demolition of the...continue reading

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