Case Digest (G.R. No. 204992) Core Legal Reasoning Model
Facts:
In Aurora Tensuan, Heirs of Dionisia Tensuan, Heirs of Jose Tensuan, Anita Tensuan, Heirs of Leyda Tensuan, Heirs of Francisco Tensuan, and Ricardo Tensuan v. Heirs of Ma. Isabel M. Vasquez (G.R. No. 204992, September 8, 2020), petitioners are the heirs of Fernando Tensuan, registered owner of a 32,862 sqm. parcel in Poblacion, Muntinlupa (TCT No. 16532, January 7, 1950). Upon his death in 1976, they executed an extra-judicial settlement, annotated on the title. In the 1980s, respondent Ma. Isabel M. Vasquez, owner of an adjacent tract in Tunasan, commissioned rip-rapping along the Magdaong River under Special Work Order (SWO) 13-000271 (1986). This activity altered the river’s course and encroached upon petitioners’ land by 1,680.92 sqm. A 1995 joint verification survey (VS-00-00368) by the Muntinlupa City Engineer confirmed the encroachment. Respondent nevertheless obtained TCT No. 144017 (November 25, 1986) covering the new land, subdivided into seven titles (TCT Nos. 180014
Case Digest (G.R. No. 204992) Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Petitioners are Aurora Tensuan, heirs of Dionisia, Jose, Leyda, Francisco, Anita and Ricardo Tensuan, represented by Amparo S. Tensuan as attorney-in-fact. They inherited Lot No. 1233 (32,862 sqm), TCT No. 16532, Poblacion, Muntinlupa City, from their father, Fernando Tensuan (d. 1976), and executed an extra-judicial settlement (May 19, 1976) duly annotated on TCT 16532.
- Respondents are the heirs of Ma. Isabel M. Vasquez. In November 1986, TCT No. 144017 (5,237.53 sqm) was issued in her name based on “Special Work Order 13-000271,” later subdivided into seven derivative titles (TCT Nos. 180014–180020).
- Rip-rapping, Surveys, Encroachment
- In the 1990s, Ma. Isabel commissioned rip-rapping along her property’s riverbank (Magdaong River), altering the river’s course and appropriating 1,680.92 sqm of petitioners’ land plus 3,556.62 sqm of the riverbed.
- Petitioners sought relief from the City Engineer’s Office; Joint Verification Survey VS-00-00368 (Apr 22–25, 1995), attended by both sides’ representatives, confirmed 1,680.92 sqm encroachment. A later survey (Feb 19, 2000) showed 2,165.73 sqm, but was not approved administratively.
- Procedural History
- RTC Branch 256, Muntinlupa: Petitioners filed on Dec 17, 1998 for accion reivindicatoria and annulment of title. Sept 16, 2010 Decision favored petitioners (voiding SWO and TCT 144017, restoring 1,680.92 sqm, awarding fees/damages). Nov 30, 2010 Order dismissed case for prescription; Dec 17, 2010 reconsideration denied.
- CA, First Division: Feb 24, 2012 reversed RTC’s dismissal and reinstated Sept 16, 2010 Decision with modification—voiding TCT 144017 and derivatives; July 4, 2012 on reconsideration reversed its own Decision, affirmed RTC’s Nov 30, 2010 Order for lack of possession and prescription; Dec 20, 2012 denied further reconsideration.
- SC G.R. No. 204992 (Sept 8, 2020): Petition for certiorari filed by petitioners assailing both CA resolutions.
Issues:
- Whether petitioners’ cause of action has prescribed.
- Whether TCT No. 144017 and its derivatives are valid or void.
- Whether the theory of accretion vests title to the river-bound land.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)