Case Summary (G.R. No. 154207)
Antecedents of the Case
The controversy centers on a parcel of unirrigated riceland, approximately 4,668 square meters, registered under Transfer Certificate of Title (TCT) No. 201367 in the names of Felicitas and Gelima Abata Abobon. The respondents filed an action before the 2nd Municipal Circuit Trial Court (MCTC) against Numeriano Abobon, asserting their rightful ownership and the need for him to vacate the land, which they had previously permitted him to use out of benevolence. Numeriano, while acknowledging family ties and the existence of the title, claimed ownership through inheritance from his parents, arguing that he had been in possession of a 3,000 square meter portion of the land for over 59 years.
MCTC Findings
The MCTC ruled in favor of the respondents, determining that they were the legal owners of the parcel based on historical transactions. Evidence demonstrated that the respondents’ parents had purchased the land from Numeriano's grandfather, and subsequent registrations confirmed this ownership. The MCTC rejected Numeriano’s claim of ownership, indicating that the land he referenced as inherited from his parents was not the same as the land in question and found that his claim lacked legal validity due to the absence of necessary documentation for the donation propter nuptias.
Regional Trial Court Decision
Numeriano appealed the MCTC ruling, but the Regional Trial Court (RTC) upheld the decision, emphasizing that the land he occupied was distinct from the land owned by the respondents. The RTC found no basis for Numeriano’s assertions and confirmed that the respondents acted within their rights to recover possession of the property.
Court of Appeals Ruling
Dissatisfied with the RTC's affirmation of the MCTC's judgment, Numeriano escalated the matter to the Court of Appeals (CA), alleging that he had rightfully possessed the land prior to the respondents acquiring it. The CA rejected his arguments, reinforcing that ownership certificates under the Torrens system enjoy presumptive validity. The CA modified the earlier ruling by deleting the MCTC's declaration of ownership concerning the parties, focusing solely on the possession of the land.
Supreme Court Ruling
In reviewing Numeriano's appeal, the Supreme Court affirmed the decision of the Court of Appeals, determining that the factual basis for ownership posited by Numeriano lacked merit. The Court articulated core principles of land registration, emphasizing the indefeasibility of Torrens titles and the prohibition against collateral attacks on such titles; hence, Numeriano could not assail the respondents’ title without initiating a proper legal challenge. The discussion underscored the notion that disputes over possession are separate from ownership claims, affirming that ownership questions remai
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Case Overview
- The case revolves around the rightful possession of a parcel of registered land disputed between petitioner Numeriano P. Abobon and respondents Felicitas and Gelima Abata Abobon.
- Respondents, as registered owners, claimed that they permitted Numeriano to use the land out of benevolence, but now required its return.
- Numeriano contended that he was the rightful owner by virtue of inheritance from his parents.
Antecedents
- Felicitas and Gelima filed an action for recovery of possession and damages against Numeriano in the 2nd Municipal Circuit Trial Court (MCTC) of Labrador-Sual, Pangasinan.
- They claimed ownership of a 4,668 square meter parcel of unirrigated riceland covered by TCT No. 201367, asserting that Numeriano had been allowed to use the land without formal agreement.
- Numeriano admitted to being a cousin of the respondents but argued that he inherited the land from his father and had continuously possessed it for over 59 years.
- He claimed that the land he cultivated was distinct from that of the respondents due to different boundaries and ownership history.
MCTC Proceedings
- The MCTC found in favor of the respondents, establishing their lineage to the original owner, Emilio Abobon, who sold the property to Leodegario Abobon (respondents' parent).
- The court traced the chain of ownership from Emilio to the respondents, including various transactions that affirmed their title and payment of taxes.
- The MCTC ruled tha