Title
Borlas vs. Court of Appeals
Case
G.R. No. L-40101
Decision Date
May 31, 1982
Plaintiffs, land owners, sued tenant Borlas for unlawful detainer. Borlas claimed ownership via Bureau of Lands permit, but SC upheld plaintiffs’ prior possession under OCT No. 5279, ruling title cannot be collaterally attacked in detainer cases.

Case Summary (G.R. No. 204944-45)

Legal Background

The case involves an unlawful detainer dispute concerning a parcel of land in Navotas, Rizal. The primary focus is on the possession and ownership of the land, highlighted through various title documents and lease agreements. The 1987 Philippine Constitution governs the legal principles relevant to this dispute.

Case History

The Municipal Court of Navotas ruled in favor of the plaintiffs, Santos and Ortiz, confirming their ownership of the land. The case proceeded to the Court of Appeals, which also upheld the plaintiffs' position, reversing a contrary ruling from the Court of First Instance of Rizal. Borlas, the defendant, then appealed to the Supreme Court.

Factual Findings by the Court of Appeals

The Court of Appeals established that Santos and Ortiz were the registered owners of the parcel of land under TCT No. 177436, with a history of ownership dating back over thirty years, as confirmed by the issuance of OCT No. 5279. Borlas, who entered into a verbal lease agreement with the plaintiffs at a monthly rental of P10.00, ceased payments by December 1966 and refused to vacate despite repeated demands.

Evidence of Ownership and Possession

Evidence presented by the plaintiffs included the registration of the land and its ownership through TCT No. 177436. In contrast, Borlas claimed possession of a foreshore area he purportedly acquired from Concordia Pascual. However, the Court of Appeals found that Borlas' leasehold did not equate to ownership, particularly given that he could not establish a claim over the land independent of the plaintiffs’ right evidenced by their Torrens Title.

Legal Question and Findings

The central legal issue explored whether the Court of Appeals correctly identified prior possession with respect to Santos and Ortiz's claims based on their certificate of title. The court found no merit in Borlas' argument concerning the cancellation of OCT No. 5279 since the documents subsequent to its issuance did not undermine the plaintiffs' prior possession. Furthermore, the Supreme Court upheld that the title in question is not subject to collateral attack in unla

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