Case Digest (G.R. No. 119281)
Facts:
Veterans Federation of the Philippines v. Court of Appeals, G.R. No. 119281, November 22, 2000, Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.The dispute concerns a parcel near the public market of San Pablo City of about 1,092 square meters. On September 6, 1963, the then owner, Manila Railroad Company of the Philippine Islands (now Philippine National Railways or PNR), executed an Absolute Deed of Sale conveying the parcel to the Veterans Federation of the Philippines (VFP) for P1,092.00; the deed described the property by a specific technical description. The deed was registered on June 18, 1964, and Transfer Certificate of Title No. T-4414 was issued to VFP, but the technical description that appeared in the certificate of title differed materially from that in the deed because the Register of Deeds copied a different description that PNR had submitted.
VFP cleared and fenced the land according to the description that had been inscribed on the title, but years later found the fence removed and permanent structures erected by private occupants who had been leasing portions of the parcel from PNR. When the occupants refused to vacate, VFP filed an accion publiciana in the Regional Trial Court (RTC), San Pablo City, Branch 32 (Civil Case No. SP-2585), naming PNR and ten lessees as defendants. Trial evidence included comparative sketch plans showing the differing technical descriptions and the occupied portions.
On January 26, 1989, the RTC declared the deed of sale valid and enforceable, ordered cancellation of TCT No. T-4414 and issuance of a new title reflecting the deed’s technical description, canceled PNR’s leases covering the sold area, ordered PNR to remove structures and surrender possession (or pay rent at P20.00 per sq. m. per month from March 25, 1986), and awarded costs; other claims and counterclaims were dismissed. The RTC denied PNR’s motion for reconsideration and partially granted VFP’s motion to clarify the surrender and rental clause.
Both sides appealed to the Court of Appeals. On July 29, 1994 the Court of Appeals modified the RTC decision by deleting paragraphs 1–3 of the dispositive portion: it dismissed the complaint against many individual defendants, ordered PNR to convey the parcel described in the deed to VFP, and ordered two occupants (Ruel Galang and Leocadio Gusti) and their families to vacate; in all other respects the RTC decision was affirmed. Motions for reconsideration were denied by the Court of Appeals.
VFP t...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in deleting the RTC’s order directing the Register of Deeds to cancel TCT No. T-4414 and to issue a new certificate of title reflecting the technical description in the Absolute Deed of Sale?
- Did the Court of Appeals err in deleting the RTC’s award of rentals and da...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
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