Case Summary (G.R. No. 246826)
Background
Spouses Yu initiated a case for prohibitory injunction, temporary restraining order, removal of a perimeter fence, and damages against Moldex Realty, Inc. and Rey Ignacio Diaz after alleging that Moldex had encroached on their property. The Yu property consists of two adjacent lots totaling approximately 8,123 square meters, as registered in their name under relevant Transfer Certificates of Title (TCT). Moldex, on the other hand, owns an adjacent property measuring over 200,000 square meters.
Initial Proceedings
The spouses contended that Moldex unlawfully constructed a fence, intruding onto a portion of their property described in TCT No. 280169. Moldex contested these claims, asserting that their construction did not encroach on any part of the Yu property and suggested that the disagreement was due to discrepancies in the technical descriptions of the property titles involved.
Joint Motion and Survey
To resolve the boundary dispute, both parties filed a joint motion in 1995 requesting the trial court to have the parcels surveyed by the Department of Environment and Natural Resources (DENR). The RTC issued an order for a ground survey, which revealed discrepancies between the actual location of the Yu property and that indicated by their titles.
Decision of the Regional Trial Court
After hearing the evidence, the RTC dismissed the Yu's complaint in 2016, ruling that there was no encroachment since Moldex's fence fell within its property boundaries as per its title. The RTC emphasized that the technical descriptions of the respective properties should be respected and could not be altered in a collateral proceeding.
Ruling of the Court of Appeals
The CA reversed the RTC decision on appeal in November 2018, ordering Moldex to remove the fence and awarding moral damages and attorney’s fees to the Spouses Yu. The CA noted that the RTC had overlooked the necessity to properly apply surveying principles to resolve the boundary discrepancy compounded by the complexities inherent in the technical descriptions of the properties.
Issues Raised
Moldex raised various arguments, citing public policy implications relating to stability in registered land ownership, the necessity of referring to issues around its title, and disputing the assessment of damages awarded against it. They also suggested that the CA had erred in not considering previous surveys presented during the trial.
Contentions of the Spouses Yu
In response, the Spouses Yu maintained that the discrepancies cited were poorly interpreted and emphasized that their titles should reflect the legal boundaries as stated. They argued that Moldex was barred from asserting a collateral attack on their title due to their prior agreements and motions in court.
Court’s Analysis and Final Ruling
The Supreme Court noted that Spouses Yu had not established their right to the disputed portion of the property on firm grounds. Even with their certificates of title on record
...continue readingCase Syllabus (G.R. No. 246826)
Introduction
- The case is a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioners are Moldex Realty, Inc. and Rey Ignacio Diaz, while the respondents are Spouses Ernesto V. Yu and Elsie Ong Yu.
- The Court of Appeals (CA) reversed and set aside the Regional Trial Court (RTC) decision, leading to a dispute regarding property boundaries and encroachment.
Antecedents
- Spouses Yu filed for a prohibitory injunction against Moldex and Diaz, claiming encroachment on their land.
- The Yu property consists of two parcels of land, registered under TCT Nos. T-280169 and T-280170.
- Moldex owns an adjacent property (Lot No. 3870) under TCT No. T-317603.
- Spouses Yu alleged Moldex encroached upon 3,159 sq.m. of their property by constructing a perimeter fence, despite demands to cease.
Moldex's Defense
- Moldex denied any encroachment, asserting that the land where the fence was built was part of its own property.
- The conflict arose from discrepancies between the technical descriptions in the Torrens titles and the actual land positions.
Joint Motion for Survey
- To resolve the boundary dispute, both parties filed a Joint Motion requesting a survey by the DENR.
- The RTC granted the motion, leading to a survey by Engr. Danilo A. Arellano, which aimed to clarify property boundaries.
RTC Ruling
- The RTC dismissed Spouses Yu's complaint, ruling there was no encroachment based on the technical descriptions in the titles.
- The RTC awarded attorney's fees to Moldex, finding its perimeter fence was within its pr