Case Summary (G.R. No. 140752)
Background and Procedural History
On September 16, 1992, the Cosmes filed a complaint for accion reivindicatoria with damages against Caraan in the Regional Trial Court (RTC) of Quezon City, asserting their ownership of the property under Transfer Certificate of Title (TCT) No. 214949. The Cosmes claimed that they had been paying realty taxes on the property and that Caraan illegally occupied it without their consent. The RTC ruled in favor of the Cosmes on August 9, 1995, ordering Caraan to vacate the property and pay damages. Caraan appealed this decision, which led the Court of Appeals (CA) to affirm the RTC decision with modifications on October 29, 1999, notably reducing the damages awarded.
Relevant Legal Issues
The primary legal issues include the validity of the Cosmes' TCT No. 214949, Caraan’s claim of ownership through adverse possession, and whether Caraan’s defense constitutes a valid challenge to the title. The Court emphasized that under Section 48 of Presidential Decree No. 1529, a Torrens title is not subject to collateral attack and cannot be altered or canceled except through a direct proceeding.
Court of Appeals Findings
The CA upheld the presumption of ownership derived from the Cosmes' registered title, concluding that Caraan’s arguments regarding possession and the spurious nature of the title were insufficient. It emphasized that mere possession does not equate to ownership if the possessor does not hold a title or have a right to ownership under the law. The CA also ruled that Caraan could not rely on a residential permit from the Bureau of Forest Development as it did not grant any right to ownership over the land.
Petitioners' Arguments
Caraan and his heirs argued that the Cosmes' TCT was based on an invalid original certificate of title (OCT) No. 614, which had been declared null and void. They maintained that having occupied the property for over thirty years, they had a superior claim through prescription. However, the Court found that the petitioners’ assertions about the validity of the title were merely collateral attacks and therefore legally insufficient to invalidate the title held by the Cosmes.
Final Decision and Rationale
The Supreme Court concluded that the petition lacked merit and affirmed the CA’s decision. Citing established jurisprudence, the Court reinforced that a registered owner has the right to possess the property covered by the title. Furthermore, the claim of adverse possession b
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Case Overview
- The case revolves around a petition for review on certiorari filed by Dionisio Caraan, represented by his heirs, seeking to set aside the Decision of the Court of Appeals dated October 29, 1999.
- The Court of Appeals affirmed, with modification, the decision of the Regional Trial Court (RTC) of Quezon City, which ordered the petitioners to vacate the property located at No. 65 Commodore St., Veterans Subdivision, Barangay Holy Spirit, Quezon City, and surrender possession to the private respondents, spouses Salcedo R. Cosme and Nora Linda S. Cosme.
Factual Background
- On September 16, 1992, the private respondents filed a complaint (accion reivindicatoria) against Dionisio Caraan in the RTC, claiming ownership of the property under Transfer Certificate of Title (TCT) No. 214949.
- The private respondents asserted that they had been paying realty taxes since 1969 and discovered the property occupied by Caraan in March 1991, which was done without their consent.
- Despite demands to vacate, which included a last written demand on August 7, 1992, the petitioner failed to comply.
- The private respondents sought possession of the property, along with compensation and damages amounting to P54,000.00, P50,000.00 in moral damages, and P50,000.00 for attorney's fees.
Petitioner’s Defense
- Dionisio Caraan, in his Answer with Counterclaim, argued that he had acquired the property through extraordinary prescription of thirty years of continuous and unin