Case Summary (G.R. No. 204626)
Factual Background
Carmeling Crisologo, through her attorney-in-fact Pedro Isican, initiated a complaint for recovery of possession against the petitioners regarding two parcels of land totaling approximately 2,000 square meters. She asserted that she was the registered owner, evidenced by Transfer Certificates of Title (TCT) Nos. T-13935 and T-13936, and alleged unlawful entry and construction by the petitioners since 2006. The petitioners contested Crisologo's ownership, claiming that her titles were void due to their origins in a declared invalid civil registration case and that they had maintained continuous possession of the properties in good faith.
MTCC Decision
The Municipal Trial Court in Cities (MTCC) ruled in favor of Crisologo on September 15, 2009, ordering the petitioners to vacate the properties, demolish their structures, and pay rentals and attorney's fees. The MTCC found Crisologo's ownership valid and the petitioners' occupation illegal, ruling that a collateral attack on the titles could not be made in a simple action for recovery of possession.
RTC Decision
On April 18, 2011, the Regional Trial Court (RTC) reversed the MTCC’s decision, asserting that the titles held by Crisologo were invalid due to the rulings in Republic v. Marcos and the subsequent Presidential Decree No. 1271, which declared said titles void. The RTC held that Crisologo failed to meet the conditions for title validation, and thus her claim could not be a basis for eviction.
CA Ruling
The Court of Appeals (CA), on June 14, 2012, reversed the RTC decision, reinstating the MTCC's ruling. The CA determined that Crisologo established her right to possess the land based on her prior acquisition and continuous payment of taxes, which indicated her ownership and claim to possession over the property.
Assignments of Error by Petitioners
The petitioners presented multiple grounds for appeal, claiming that the CA erred in finding that Crisologo had actual or prior possession of the disputed land, in the evaluation of sale documents from 1967, and in interpreting tax declarations and the appointment of Isican as administrator as proof of possession. They contended that Crisologo's claim was insufficient and subject to legal challenges based on the invalidity of her titles.
Respondent's Position
Crisologo's position included technical objections regarding the petitioners' standing to appeal and procedural failings in their motion for extension of time. She maintained that her ownership and possession rights were legitimate based on her continuous management of the property.
Legal Principles: Accion Publiciana
The Court discussed the nature of accion publiciana, emphasizing that it seeks to determine the better right of possession rather than ownership. In this context, possession is treated separately from ownership, allowing the court to adjudicate claims based on possession while ownership issues may still be resolved in other actions.
Nullity of Titles Under P.D. No. 1271
The Court clarified that while Section 1 of P.D. No. 1271 declared certain titles void, this nullity was not absolute. The certificate of title issued before a specified date could still be valid if conditions like proof of non-inclusion in government reservations and tax payments were met. The pet
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Background and Context
- This case revolves around a petition for review on certiorari under Rule 45, regarding the possession of two parcels of land.
- The initial ruling by the Municipal Trial Court in Cities (MTCC) was in favor of Carmeling Crisologo, who claimed ownership and possession based on her certificates of title.
- The Regional Trial Court (RTC) later reversed the MTCC's decision, leading to an appeal to the Court of Appeals (CA), which reinstated the MTCC's ruling.
Parties Involved
- Petitioners: Paul P. Gabriel Jr., Ireneo C. Calwag, Thomas L. Tingga-an, and the heirs of Juliet B. Pulkera.
- Respondent: Carmeling Crisologo, who filed a complaint for recovery of possession against the petitioners.
Facts of the Case
- Crisologo claimed to be the registered owner of two parcels of land totaling approximately 2,000 square meters, supported by Transfer Certificates of Title (TCT) Nos. T-13935 and T-13936.
- She asserted that she discovered unlawful occupation by the petitioners in 2006, who had constructed houses on her property without her consent.
- Despite verbal demands for the petitioners to vacate, they refused, claiming the titles were void due to prior Supreme Court rulings and Presidential Decree (P.D.) No. 1271.
Initial Rulings
MTCC Decision
- On September 15, 2009, the MTCC ruled in favor of Crisologo, ordering the petitioners to vacate the properties, dismantle their structures, and pay rentals and attorney's fees.
- The court upheld Crisologo's ownership based on her registered titles, indicating that the petitioners could not challenge the validity of these titles in a simple recovery action.
RTC Decision
- The RTC reversed the MTCC ruling on April 18, 2011, asserting th