Case Summary (G.R. No. 181268)
Factual Background
Milagros Hernandez alleges that in 1985, she purchased two parcels of land from Romeo Uy An, identified as Lot 8 Block 3 and Lot 6 Block 3 in Biñan, Laguna, evidenced by a deed of sale. Following the purchase, she and her family maintained continued, open, and adverse possession of the properties. After entrusting the registration of these properties to her son-in-law Ricardo San Andres, who passed away in 1991 without completing the title transfer, Hernandez resided in the United States and remained unaware of the unregistered status of the lots. In 2002, Hernandez received a letter from an attorney representing Felicitas Mendoza, demanding that she vacate the property, revealing a deed of sale executed by An in 1989, which transferred these properties to Mendoza and Edwina Ocampo.
Procedural History
Hernandez and her family eventually discovered that both parcels were mortgaged, leading to extrajudicial foreclosure and their subsequent sale at public auctions to PSB and Metrobank. Following these events, both banks pursued the issuance of writs of possession. Hernandez initiated a legal action for the annulment of the Transfer Certificates of Title (TCT) against the respondents, alleging bad faith in the acquisition of the titles by Mendoza and Ocampo. The RTC denied Hernandez’s motion for a temporary restraining order to prevent the enforcement of the writs of possession based on the claim that issues of title must be resolved through trial, given that both banks had clean titles unencumbered by prior claims.
Court of Appeals' Ruling
The Court of Appeals upheld the RTC decision, dismissing Hernandez’s petition for certiorari. It found no grave abuse of discretion in the RTC’s refusal to issue a preliminary injunction, asserting that Hernandez failed to establish a clear right to the properties. The appellate court recognized the TCTs in the names of Mendoza and Ocampo as superior documents and reasoned that Hernandez needed to prove the fraudulent acquisition of these titles, which she had not done. Furthermore, the CA emphasized the propriety of the writs being strictly ministerial actions that could not be contested through an injunctive plea filed in a concurrent case.
Supreme Court Decision
The Supreme Court affirmed the CA ruling, rejecting Hernandez's assertion that she was entitled to an injunction based on her claims of due process violations and non-participation in the foreclosure proceedings. The Court clarified the nature of writs of possession, noting that such orders are issued only when specific conditions are met, particularly when no third-party claims to adverse possession are substantiated. The justices observed that Hernandez had not established a clear and unequivocal claim to the properties, as the possession she claimed was disputed by the banks, who contended that the properties were unoccupied at the time of their inquiries.
Analysis of Legal Principles
The proceedings highlighted fundamental legal principles concerning the nature of possession, ownership rights, and
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Case Reference
- G.R. No. 181268
- Decision Date: August 15, 2016
- Division: Third Division
- Reported in: 792 Phil. 854
Procedural History
- This case originates from a Petition for Review on Certiorari filed under Rule 45 of the Revised Rules of Court.
- It challenges the Decision dated September 24, 2007, of the Court of Appeals (CA) in CA-G.R. SP. No. 90050.
- The CA's decision affirmed the Order dated November 30, 2004, of the Regional Trial Court (RTC) of Binan, Laguna, Branch 24 in Civil Case No. B-6191 for Annulment of Deed of Sale and Transfer Certificates of Title (TCT).
- The RTC's ruling was followed by a Resolution dated January 14, 2008, which denied Hernandez's Motion for Reconsideration.
Facts of the Case
- Petitioner: Milagros Hernandez, represented by her attorney-in-fact, Fe Hernandez-Arceo.
- Property Transactions:
- In 1985, Hernandez acquired two parcels of land from Romeo Uy An: Lot 8 Block 3 and Lot 6 Block 3 located in Binan, Laguna, evidenced by a deed of sale.
- She was in continuous, open, and adverse possession of these lots since the purchase.
- Hernandez entrusted the registration of these lots to her son-in-law, who died in 1991 without completing the registration.
- Discovery of Fraudulent Title:
- In 2002, Hernandez received a letter from Atty. Agapito Carait, representing Felicitas R. Mendoza, demanding vacation of Lot 8.
- Hernandez learned that the titles to the lots were registered in the names of Mendoza and Edwina Ocampo due to a Deed of Sale executed by An in 1989.
- Both lots were mortgaged; Lot 8 with Metrobank and Lot