Title
Supapo vs. Spouses De Jesus
Case
G.R. No. 198356
Decision Date
Apr 20, 2015
Registered landowners Spouses Supapo sought recovery of possession of their Novaliches lot, occupied by respondents without consent. SC ruled in their favor, affirming MeTC jurisdiction, imprescriptibility of Torrens title, and no res judicata bar.

Case Digest (G.R. No. 198356)
Expanded Legal Reasoning Model

Facts:

  • Parties and Property
    • Petitioners Esperanza Supapo and the heirs of Romeo Supapo hold Transfer Certificate of Title No. C-28441 over Lot 40, Block 5, Novaliches, Quezon City, with an assessed value of ₱39,980.00.
    • Respondents spouses Roberto and Susan de Jesus and Macario Bernardo built and occupied two houses on the subject lot without petitioners’ knowledge or consent in 1992.
  • Procedural History
    • Petitioners sought amicable settlement before the Lupong Tagapamayapa and filed a criminal complaint under PD 772 (Anti-Squatting Law); the RTC convicted respondents and ordered vacatur, but the conviction was later dismissed by the CA after PD 772 was repealed by RA 8368.
    • Petitioners moved for civil execution of the vacatur order; the RTC denied the writ’s quashal and motion for reconsideration; respondents secured a CA certiorari annulment of the writ on jurisdictional and prescription grounds.
    • On March 7, 2008, petitioners filed an accion publiciana for recovery of possession before the MeTC of Caloocan City; the MeTC denied respondents’ motion for preliminary hearing; the RTC and CA both granted certiorari, dismissing the case for lack of jurisdiction and prescription.

Issues:

  • Whether the MeTC properly acquired jurisdiction over the accion publiciana given the assessed value of the property.
  • Whether the petitioners’ cause of action has prescribed under Article 555 of the Civil Code.
  • Whether the accion publiciana is barred by res judicata based on the prior criminal proceedings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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