Case Summary (G.R. No. 120827)
Factual Background
Life Homes Realty Corporation is the registered owner of two parcels of land in Barrio Ampid, San Mateo, Rizal, covered by TCT Nos. N-28603 and 31730, designated for residential purposes. Adjacent to these lots is a parcel registered to Marvi Development, Inc. under TCT No. 309740. The contention centered on a discovered encroachment of Marvi’s property upon Life Homes’ land, specifically affecting approximately 10,365 square meters. As a result, both parties agreed to a relocation survey by a government geodetic engineer to resolve boundary disputes.
Relocation Survey Findings
The independent survey, executed by Government Geodetic Engineer Felipe R. Venezuela, concluded that the survey conducted by Life Homes’ geodetic engineer was correct. It noted that the encroachment was based on faulty prior surveys of Marvi's plots. This report raised issues regarding the proper technical descriptions and methodologies used in both parties’ original title surveys. Consequent to these findings, Life Homes demanded Marvi vacate the encroaching area.
Litigation Developments
Life Homes subsequently filed a complaint for recovery of possession and damages in the Regional Trial Court (RTC) of San Mateo. Marvi countered the complaint, claiming that the survey upon which Life Homes relied was baseless due to recognized defects in the engineering survey and insufficient judicial approval of the survey amendments. On May 21, 1992, the RTC dismissed both the complaint and counterclaim, highlighting the inadequacy of the Venezuela report concerning the legal validity necessary under prior court rulings concerning property titles.
Court of Appeals Decision
Both parties appealed the RTC's decision to the Court of Appeals (CA). The CA affirmed the RTC's ruling, asserting that the Venezuela report lacked binding authority, emphasizing that adjustments required court approval and that the ordinary civil action filed by Life Homes was not appropriate for asserting their claim of recovery. The CA held that any corrections to technical descriptions of properties evidenced by title must be processed through proper applications to the original Land Registration Court.
Supreme Court Evaluation
Life Homes appealed to the Supreme Court, challenging the CA’s interpretation of the Venezuela report's binding nature and the necessity of a court order for adjustments indicated in the geodetic engineer’s report. The Supreme Court concurred with the lower court's reasoning, reinforcing that there was no explicit agreement that the relocation survey&#
...continue readingCase Syllabus (G.R. No. 120827)
Case Overview
- The case originates from an appeal by Life Homes Realty Corporation (petitioner) against the Court of Appeals (CA) ruling that dismissed its appeal concerning a civil action for recovery of possession against Marvi Development, Inc. (respondent).
- The CA concluded that the ordinary civil action for recovery of possession was not the appropriate remedy for the petitioner.
Facts of the Case
- Life Homes Realty Corporation is the registered owner of two parcels of land in Barrio Ampid, San Mateo, Rizal, covered by Transfer Certificate of Title (TCT) No. N-28603 and TCT No. 31730, subdivided for residential purposes.
- Marvi Development, Inc. owns an adjacent property under TCT No. 309740, also subdivided for residential use.
- In 1979, Life Homes discovered that parts of its property were encroached upon by Marvi, totaling an area of 10,365 square meters, prompting a request for a government survey to resolve boundary disputes.
Survey and Findings
- An independent survey was requested on May 11, 1981, leading to a verification survey conducted by Government Geodetic Engineer Felipe R. Venezuela.
- The Venezuela report outlined discrepancies in the property boundaries, indicating that the survey by Life Homes’ engineer, Regino Natividad, was correct, and recommended that Marvi’s survey be re