Case Summary (G.R. No. 146513)
Relevant Property History
Macaria Capuno originally owned two lots, selling a portion (254.03 square meters) to the spouses Alejandro Miranda and Feliza Garcia on March 31, 1953. The spouses later had the property surveyed and acquired a definitive technical description of the land. In 1960, Capuno applied to register her ownership of the lots, a move unopposed by the spouses, resulting in a favorable judgment for Capuno on November 26, 1960.
Transfer of Ownership
Subsequent to the registration, Capuno sold a separate lot (Lot 18) to Atty. Tomas Besa, who, alongside his wife Espiranza, later divided this property into several lots. After Capuno’s annulment suit against the Besas was dismissed, the latter sold portions of the divided property to Circle Drug Corporation. Respondent Besa eventually took ownership of Lot 18-F-3-B-2-B, which the Petitioner unlawfully occupied.
Unlawful Detainer Case
Respondent filed a complaint for unlawful detainer against the Petitioner in 1997, claiming ownership and the right to possession. Following trial proceedings, the Municipal Circuit Trial Court ruled in favor of the Respondent, leading to appeals by the Petitioner through the Regional Trial Court (RTC) and ultimately the Court of Appeals, which upheld the lower court's ruling regarding possession.
Legal Arguments and Issues Raised
The Petitioner raised multiple points of contention on appeal: jurisdictional issues over the subject matter, a claimed right to occupy based on her family’s long-term residence, alleged fraud in the title transfer to the Respondent, and alleged defects in the ejection complaint for lack of necessary parties. The crux of the appeal revolved around the assertion of ownership and questions regarding lawful possession.
Jurisdiction and Ejectment Proceedings
The Supreme Court ruled that the lower courts maintained jurisdiction despite the Petitioner’s claims of ownership, as ownership assertions do not strip a court of jurisdiction in ejectment cases. It emphasized that while the Petitioner asserted that she had been in adverse possession for many years, such matters of ownership are to be resolved in separate actions and are not determinative in ejectment proceedings.
Findings on Ownership and Possession
The Court reaffirmed the principle that a registered owner has the right to possession of their property, regardless of the claims to ownership made by a party in possession. Distinguishing between an ownership claim and a possessory remedy function, the ruling noted that the titles conferred by the Register of Deeds establish a legal right, which the Respondent exercised lawfully.
Final Verdi
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Case Background
- The case involves a petition for review on certiorari brought before the Supreme Court by Lucia G. Miranda against Esperanza B. Besa, originating from an unlawful detainer case.
- The dispute centers on a property owned by Macaria Capuno, consisting of two lots in Capas, Tarlac, which were the subject of a series of transactions and legal actions.
- The case highlights the complexities of property ownership, possession rights, and the legal implications of a deed of sale.
Property History
- Macaria Capuno owned two lots, namely Lot 11 and Lot 18, in Capas, Tarlac.
- On March 31, 1953, Capuno executed a deed of absolute sale transferring a portion of the property (254.03 square meters) to the Spouses Alejandro Miranda and Feliza Garcia.
- In 1960, Capuno applied for the registration of the two lots, which was granted by the Court of First Instance, thus declaring her as the absolute owner.
Subsequent Transfers and Legal Actions
- On March 6, 1967, Capuno sold Lot 18 to Atty. Tomas Besa, who subsequently subdivided the property into several lots.
- A complaint was filed by Capuno against the Spouses Besa to annul the sale in 1968, which was ultimately dismissed.
- Atty. Tomas Besa later sold portions of the subdivided lots to Circle Drug Corporation, and the titles changed hands multiple times.
Ejectment Complaint
- On September 3, 1997, Besa filed a complaint for unlawful de