Case Summary (G.R. No. L-4935)
Nature and Evolution of the Complaint
The plaintiff’s complaint was amended three times concerning the extent and description of the land in dispute. Initially, the land was described as a 13-hectare portion under Transfer Certificate of Title (TCT) No. 37686. After the defendant identified the portion he claimed, the plaintiff reduced the area to approximately 6 hectares. Further amendments occurred following surveyors’ testimonies indicating overlap with another titled land under TCT No. 37677 and later to conform to the evidence presented during the trial that the defendant's occupied area was around 13 hectares. These amendments were allowed by the court to align the pleadings with the actual evidence.
Defendant’s Answer and Claims
The defendant claimed ownership through prescription based on alleged open, continuous, exclusive, public, and notorious possession adverse to all others "from time immemorial." He also asserted that the plaintiff or its predecessors obtained registration fraudulently or without proper notice to him or his predecessors. The defendant prayed for dismissal of the complaint with costs and for the plaintiff either to reconvey the land or compensate him for its value.
Lower Court’s Ruling and Relief Granted
The Court of First Instance ruled in favor of the plaintiff, declaring the defendant without any right to the disputed land. The defendant was ordered to restore possession to plaintiff and to pay monthly rent of ₱132.62 from January 1940 until vacating the property, as well as to bear the costs of the suit.
Defendant’s Appeal and Assigned Errors
Defendant’s appeal raised multiple errors: that the plaintiff was not the real party in interest; improper admission of the third amended complaint; denial of motions to strike; inclusion in the judgment of land not involved; erroneous holding that the disputed land was covered by plaintiff’s TCTs; incorrect finding that defendant was not owner; error in obliging defendant to pay rent; and failure to order reconveyance of the land to defendant.
Real Party in Interest and Legal Representation
The court found no merit in the claim that plaintiff was not the real party in interest. The Rules of Court require only that an action be brought in the name of the real party in interest, not necessarily by the real party personally. Representation by counsel or even another corporation (Gregorio Araneta, Inc. as managing partner) is permissible, particularly when the joint venture aligns with the authorized corporate business. The objection regarding illegality of a corporation acting as a managing partner in a partnership was dismissed with reference to established legal principles on joint ventures.
Admission of Amendments Conforming to Evidence
The trial court’s allowance of the third amended complaint was proper under Section 4, Rule 17 of the Rules of Court, which permits amendments to conform pleadings to the evidence, including post-judgment amendments if necessary. Courts favor such amendments when they serve the merits, barring prejudice to the other party. The failure to amend does not necessarily invalidate the trial’s outcome on issues proven but not formally pleaded.
Ownership and Coverage Under Torrens Titles
Initially, defendant admitted that the land in dispute related to Exhibit A and B marked with his name. Despite changing counsel and theory, defendant failed to prove that plaintiff’s certificates of title did not cover the land. Evidence demonstrated that the disputed portion is part of two titled lots (Nos. 4-B-3-C and 4-B-4) registered under TCT Nos. 37686 and 37677 respectively, originally registered in 1914. Testimonies from witnesses on both sides confirmed this identification.
Because the land is covered by valid Torrens titles issued more than a year prior, the registration decree is conclusive and immune from attack on grounds of fraud, error, or lack of notice. Collateral attack by a claimant without registration is prohibited, and ownership cannot be acquired by prescription or adverse possession against the registered owner under Section 46 of Act No. 496. The right to secure possession under the Torrens system is indefeasible and cannot prescribe, consistent with prior Supreme Court rulings.
Obligation to Pay Rent for Use and Occupation
The court correctly found defendant must pay reasonable compensation from January 1940 until he vacates. The rental amount of ₱132.62 per month was based on stipulated compensation of ₱10 per hectare for the 13.2619 hectares occupied by defendant. Evidence showed that ejectment proceedings had been initiated as early as 1939, and defendant’s long-asserted claim of ownership negated payment of rent, rendering the rental award just and proper.
Motion to Dismiss for Parallel Case and Final Outcome
During the appeal, defendant moved to dismiss the case citing a purported pending
Case Syllabus (G.R. No. L-4935)
Nature of the Case and Origin
- The case is an action to recover possession of a registered land located in barrio Tatalon, Quezon City.
- Initially filed in the Court of First Instance of Rizal, Quezon City Branch.
- The plaintiff’s complaint underwent three amendments concerning the extent and description of the land sought to be recovered, reflecting adjustments responding to evidence and claims during trial.
- The initial complaint described the land as part of a 13-hectare lot; subsequently reduced to 6 hectares, then amended again to conform to surveyors’ testimony and evidence, with the final area being around 13 hectares.
Plaintiff’s Title and Land Description
- The land consists of two main lots: lot No. 4-B-3-C (approximately 5,297,429.3 square meters) and lot No. 4-B-4 (approximately 74,789 square meters), both situated in barrio Tatalon, Quezon City.
- These lots are covered by Transfer Certificate of Titles (TCT) Nos. 37686 and 37677, respectively, originally registered on July 8, 1914, under original Certificate of Title No. 735.
- Plaintiff’s ownership was established by credible testimony from witnesses Antonio Manahan and Magno Faustino, and corroborated by defendant’s witness, Quirico Feria, who attested to the exact location and extent of defendant’s occupation within the said lots.
Defendant’s Claims and Answer
- Defendant asserted prescription and title based on “open, continuous, exclusive and public and notorious possession” under claim of ownership, adverse to all others, and extending from “time immemorial.”
- Alleged that plaintiff or its predecessors obtained registration by “fraud or error” and without knowledge or notice (personal or published) to defendant and predecessors.
- Requested dismissal of the complaint with costs and demanded reconveyance of the land or payment of its value.
Trial Court Findings and Judgment
- The trial court ruled in favor of the plaintiff, finding defendant had no rights to the land.
- Ordered defendant to restore possession to plaintiff and to pay monthly rent of ₱132.62 from January 1940 until he vacated the land.
- Costs were imposed on the defendant.
Defendant’s Assignments of Error
- Contesting plaintiff’s standing as the real party in interest.
- Alleging error in admission of the third amended complaint.
- Challenging denial of defendant’s motion to strike.
- Claiming inclusion of land not involved in litigation.
- Disputing the coverage of the land by the specific Transfer Certificates of Title.
- Insisting that defendant is the lawful owner.
- Disputing the imposition of rental pa