Case Summary (G.R. No. 210528)
Circumstances of the Case
The Respondent's claim is based on her successful registration of the property, which was finalized by the RTC's Decision dated November 3, 1998. The parcel of land consists of approximately 20,149 square meters and is described in detail, including its boundaries and neighboring properties. The Petitioners opposed the issuance of the writ of possession, arguing their long-standing actual physical possession of the land since 1964, despite not being recognized as parties to the initial registration case.
Petitioners' Arguments
The Petitioners contended that the RTC acted with grave abuse of discretion by issuing the writ of possession. They provided evidence of their continuous ownership claims, including a Sales Application from 1986 and a Declaration of Real Property covering the years preceding the RTC’s decision. They asserted that their established possession debarred the issuance of the writ in favor of the Respondent.
Procedural Issues and Legal Framework
The Respondent argued that the Petitioners' appeal should have proceeded to the Court of Appeals based on the hierarchy of courts, but the Court clarified that the Petition for Review on Certiorari under Rule 45 of the Rules of Court was correctly filed, as it raised only questions of law. The Court emphasized that questions of law pertain to the correct application of legal principles rather than factual disputes.
Substantive Legal Issues
The crux of the case involved the propriety of the RTC's issuance of the writ of possession. It was established that such a writ is typically a ministerial duty following a finalized registration decision. However, this duty may be contested when actual possessors of the land under a claim of ownership are involved. The Court recognized that actual possession is presumed to indicate ownership and thus requires judicial intervention to resolve such disputes. This notion is backed by the Civil Code which mandates that true owners must pursue judicial processes to reclaim property unlawfully possessor by others.
Court's Findings
The Court found that the RTC erred in granting the writ of possession given that the Petitioners had already proven their claim to possession. The existence of a prior judgment where the Municipal Trial Court dismisse
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Case Overview
- The case involves a Petition for Review on Certiorari challenging an Order issued by the Regional Trial Court (RTC) of Olongapo City, Branch 72, which granted a writ of possession to respondent Soledad Salinas.
- The RTC's Order was issued in the context of a land registration case (LRC Case No. N-04-0-97) following a favorable judgment regarding Salinas's application for land registration.
- The land in question is a parcel located in the Barrio of Barretto, Olongapo City, with specific boundaries and an area of 20,149 square meters.
Background of the Case
- Respondent Soledad Salinas applied for land registration, and the RTC ruled in her favor on November 3, 1998, issuing Original Certificate of Title (OCT) No. P-10053.
- Petitioners, the Mendoza family, opposed the issuance of a writ of possession, claiming they were not part of the registration case and had been in actual physical possession of the property since 1964.
- The RTC rejected the petitioners' claims and issued the writ of possession on April 2, 2002.
Petitioners' Arguments
- The petitioners asserted that the RTC erred in issuing the writ of possession, claiming they had actual possession of the property since 1964, supported by evidence including a Sales Application by Gerardo Mendoza and a Declaration of Real Property for the years 1976 and 1985.
- They contended that they should not be ousted from their possession without due process and that their status as actual possessors under a clai