G.R. No. L-25894 - Bolanos vs. J.M. Tuason and Co., Inc.

The case involves an appeal by J.M. Tuason & Co., Inc. and People's Homesite & Housing Corporation against an order from the Court of First Instance of Rizal.
The order, dated September 9, 1965, was issued in response to a petition filed by Quirino Bolaos and others, seeking to prevent any disturbance of their possession of a parcel of land pending a Supreme Court decision.
The land in question comprises 13.2619 hectares and is covered by Transfer Certificates of Title (TCT) Nos. 37677 and 37686.

The dispute originated from a previous case where J.M. Tuason & Co., Inc. sought to recover possession of the same parcel of land from Quirino Bolaos.
The lower court ruled in favor of J.M. Tuason, and Bolaos subsequently appealed to the Supreme Court, which affirmed the lower court's decision in 1954.
In a separate set of civil cases, the court declared Original Certificate of Title No. 735 null and void, which the petitioners argued affected the validity of the TCTs in question.

The petitioners requested a general injunction to prevent any disturbance of their possession of the land until the Supreme Court resolved the appeal regarding the validity of the TCTs.
The petitioners claimed they had been in continuous possession of the land since the initiation of the civil action against them.
The court published the petition in a newspaper, and the order was granted, enjoining the respondents from disturbing Bolaos's possession.

The appellants contended that the lower court erred in several respects, including:
- Failing to recognize that the petition was barred by the prior judgment in G.R. No. L-4935.
- Proceeding without jurisdiction over the subject matter of the petition.
- Incorrectly assuming that the Supreme Court's decision had not been executed and that Bolaos remained in possession of the land.
- Erroneously issuing the order dated August 5, 1965.

The relief sought by the petitioners was essentially a broad preliminary injunction against all parties to prevent any disturbance of their alleged possession.
The basis for the injunction was the pending appeal regarding the nullity of Original Certificate of Title No. 735, which the petitioners argued affected their TCTs.
The order did not specify a duration for the injunction, raising concerns about its scope and implications.

The court found that the trial court lacked jurisdiction to issue the injunction, as the matter of possession falls outside the scope of the land registration court's authority after a decree has been issued.
The court emphasized that once a land registration proceeding concludes, the jurisdiction of the land registration court is limited to issuing writs of possession, if necessary.
The court noted that no legal provision allows a land registration court to resolve possession issues after the original registration proceedings have ended.

The court highlighted that the annulment of Original Certificate of Title No. 735 does not automatically invalidate other tit...continue reading