Case Summary (G.R. No. 211253)
Factual Antecedents
The dispute arose after Demavivas and her co-plaintiffs filed a complaint against Demegillo for "accion publiciana," claiming they were the rightful owners of the land in question. Prior to the events leading to the litigation, Demegillo alleged that he had lawful ownership over a 3-hectare portion of Lot 3106 since 1974 and contended that he had entered into a written agreement with Adolfo Lumampao (the deceased father of Demavivas) for the subdivision of the land. A Certificate of Land Ownership Award (CLOA) was issued to Demavivas and her co-plaintiffs, later resulting in the issuance of OCT No. D-4960, which they claimed as valid and indefeasible.
RTC Ruling
The Regional Trial Court (RTC) ruled in favor of Demegillo, finding that the issuance of CLOA No. 00029958 (which the petitioners relied on) erroneously covered the 3-hectare portion occupied by him. The RTC emphasized that Demegillo had been in continuous possession of the disputed land and condemned the petitioners for acting in bad faith, ordering them to pay damages to Demegillo and directing the cancellation of OCT No. D-4960.
Court of Appeals Decision
The Court of Appeals (CA) reversed the RTC decision, declaring Demavivas and her co-plaintiffs as the rightful owners based on the indefeasibility of their title after the expiration of one year from the CLOA issuance. It found that the RTC had no jurisdiction to alter the registered title of the land, noting that the matter of ownership had been conclusively settled in favor of Demavivas and her co-plaintiffs by the DARAB’s prior ruling, which the RTC improperly reviewed.
Issues Presented
In G.R. No. 211253, Demegillo raised multiple issues, primarily challenging the CA's declaration of ownership, the jurisdiction of the RTC to order registration in his name, and the propriety of the DARAB's conclusions on his alleged lack of standing as a mere applicant. In G.R. No. 211259, Demavivas contended the CA failed to address her claims for damages, effectively rendering the victory hollow.
Supreme Court Ruling
In addressing the petitions, the Supreme Court focused on the fundamental issue of better right of possession. The Court confirmed that the findings of the DARAB, which concluded Demegillo had no vested right in the property, are binding and conclusive. The Court reaffirmed the principle that a Torrens title, once registered, is indefeasible and can only be challenged within a specific timeframe, which had lapsed in this case. The Court further concluded that Demegillo's assertions regarding prior possession did not confer him standing to contest the title
Remand for Further Proceedings
While affirming the CA's decision in G.R. No. 211253, the Supreme Court partially grante
...continue readingCase Syllabus (G.R. No. 211253)
Overview of the Case
- This case involves consolidated petitions for review on certiorari related to a land dispute over a parcel of land (Lot 3106) in Trento, Agusan del Sur.
- The petitions challenge the decisions of the Court of Appeals (CA) that reversed the Regional Trial Court's (RTC) prior judgment, which had favored petitioner Celedonio C. Demegillo as the lawful owner of a portion of the land.
- The CA's decisions were rendered on May 30, 2013, and January 15, 2014.
Factual Antecedents
- The dispute arose from a complaint for accion publiciana filed by respondents Concepcion L. Demavivas and co-plaintiffs against Demegillo, claiming ownership and possession of Lot 3106, which had an area of 95,689 square meters.
- The land was originally registered under the names of Demavivas, Lumampao, Fancobila, and Babaan, following a Certificate of Land Ownership Award (CLOA) issued by the Department of Agrarian Reform (DAR) in favor of Adolfo Lumampao, the deceased father of the respondents.
- Demegillo claimed he had been in possession of a 3-hectare portion of Lot 3106 since 1974 and alleged that his rights were violated when the land was awarded to Demavivas and her co-plaintiffs.
Development of the Dispute
- Demegillo filed a complaint with the Department of Agrarian Reform Adjudication Board (DARAB) for the cancellation of the CLOA, asserting that it erroneously included his claimed portion of the land.
- The PARAD dismissed Demegillo's complaint, stating he lacked legal