Case Summary (G.R. No. 146259)
Key Dates and Procedural Posture
Occupancy by petitioners and their predecessors-in-interest since 1910. Respondents discovered superior title in or about May 10, 1982. Complaint for recovery of possession and damages filed January 22, 1988 (RTC, Branch 24, Biñan, Laguna; Civil Case No. B-2777). RTC rendered judgment for respondents on March 24, 1995. Court of Appeals affirmed on September 8, 2000; its denial of petitioners’ motion for reconsideration was rendered November 20, 2000. Petition for review by certiorari to the Supreme Court followed, decision rendered September 13, 2007.
Factual Background
Petitioners occupied and built houses and an apartment building on the lot they believed to be Lot No. 1580, evidenced by Transfer Certificate of Title (TCT No. T-40624) issued by the Registry of Deeds of Laguna. Respondents asserted ownership of Lot No. 1580 under Certificate of Title No. RT-599 (10731) and alleged petitioners’ occupation was without right. The trial court, upon agreement of the parties, commissioned a resurvey by Engr. Romulo Unciano of the Bureau of Lands (Region IV). The resurvey, approved by the Bureau of Lands, showed that the lot actually occupied by petitioners was Lot No. 1580 registered in the name of Margarita Almada (respondents’ predecessor-in-interest), whereas the lot covered by TCT No. T-40624 corresponded to Lot No. 1581, registered in the name of Servillano Ochoa (petitioners’ predecessor-in-interest) and occupied by another person (Isidro Jasmin).
Trial Court and Appellate Rulings
The RTC declared respondents the true and lawful owners of Lot No. 1580, ordered defendants (petitioners) to deliver peaceful physical possession and to remove their structures, and awarded P30,000 as attorney’s fees and litigation expenses. The Court of Appeals affirmed the RTC judgment. The Supreme Court was then presented with petitioners’ challenge by petition for review on certiorari under Rule 45.
Issues Presented
- Whether petitioners are the owners of Lot No. 1580; and 2) whether respondents’ action is barred by prescription/adverse possession. As an ancillary issue, the case raised whether respondents, upon reasserting possession, must compensate petitioners for the buildings and improvements they constructed.
Standard of Review on Certiorari
The Supreme Court emphasized the constrained scope of review in a Rule 45 petition: only questions of law may be raised. The Court will not reweigh or re-evaluate factual findings of the trial court and the Court of Appeals except in limited circumstances, including when factual findings are contradictory, when an inference is manifestly mistaken or absurd, when judgment is premised on misapprehension of facts, or when relevant facts were left unresolved and would justify modification or reversal.
Supreme Court’s Treatment of Ownership Claim
The ownership claim by petitioners was factual in nature and required reassessment of the evidence already weighed by the lower courts—specifically the resurvey results. Because the dispute over which titled parcel corresponds to the physical lot requires factual determination, the Supreme Court declined to disturb the lower courts’ findings. The resurvey’s conclusion that the parcel physically occupied by petitioners is the titled Lot No. 1580 registered to Margarita Almada formed the factual basis for the determination that respondents are the true owners.
Prescription and Registered Land
The Court applied the settled rule that title to registered land in derogation of the registered owner cannot be acquired by prescription or adverse possession. Likewise, prescription cannot be asserted against hereditary successors of a registered owner because they are juridically the continuation of the decedent’s personality. Thus, petitioners could not successfully invoke prescription to defeat the registered title held by respondents’ predecessor-in-interest.
Good Faith, Legal Principles on Improvements, and Relevant Civil Code Provisions
The Court analyzed whether petitioners were builders in good faith. Good faith entails an honest belief in the validity of one’s right, absence of malice or design to defraud, and ignorance of any superior claim. Applied to possession, a possessor in good faith does not know of flaws in title or superior rights affecting his acquisition. The Court relied on Civil Code provisions that govern improvements and expenses:
- Article 448: owner of land on which something has been built in good faith may appropriate the works after payment of indemnity (or oblige the builder to pay for the land), and the builder may not be compelled to buy the land if its value considerably exceeds the value of the improvements; in such a case reasonable rent may be imposed.
- Article 546: necessary expenses shall be refunded to every possessor; only a possessor in good faith may retain the thing until reimbursed.
- Article 548: expenses for mere luxury are not refundable to the possessor in good faith, though removable ornaments may be taken if no injury results and successors do not prefer reimbursement.
Application of Good Faith and Remedies to the Case
Using these parameters, the Court found petitioner
...continue readingCase Syllabus (G.R. No. 146259)
Facts of the Case
- Since 1910, petitioners and their predecessors-in-interest have been occupying a parcel identified in the proceedings as Lot No. 1580 consisting of 886 square meters situated in Malaban, Biñan, Laguna, on which they built houses and an apartment building.
- The parcel occupied by petitioners was covered by Transfer Certificate of Title (TCT) No. T-40624 issued by the Registry of Deeds of Laguna.
- On May 10, 1982, respondents Mauro Apeta and Apolonia Almazan discovered that they were the true owners of Lot No. 1580 being occupied by petitioners.
- On January 22, 1988, respondents filed a complaint for recovery of possession and damages with the Regional Trial Court (RTC), Branch 24, Biñan, Laguna, docketed as Civil Case No. B-2777, alleging ownership of Lot No. 1580 covered by Certificate of Title No. RT-599 (10731).
- Petitioners answered, specifically denying respondents’ allegations and asserting ownership of Lot No. 1580 as shown by TCT No. T-40624.
- By agreement of the parties during trial, the RTC commissioned Engr. Romulo Unciano of the Bureau of Lands, Region IV, to conduct a resurvey of the disputed property; the resurvey, approved by the Bureau of Lands, showed that the lot occupied by petitioners and claimed by respondents as Lot No. 1580 was registered in the name of Margarita Almada (respondents’ predecessor-in-interest).
- The resurvey further showed that the lot covered by TCT No. T-40624 is not Lot No. 1580 but Lot No. 1581, registered in the name of Servillano Ochoa (petitioners’ predecessor-in-interest) and occupied by Isidro Jasmin.
Trial Court Disposition
- On March 24, 1995, the RTC rendered judgment in favor of respondents, declaring them the true and lawful owners of Lot No. 1580 covered by RT-599 (10731), and declaring defendants (petitioners) without right to continue in possession.
- The RTC ordered the defendants and those acting for them to deliver peaceful physical possession of Lot No. 1580 to plaintiffs (respondents) and to remove their houses and apartment building thereon.
- The RTC ordered the defendants to pay jointly and severally to plaintiffs the amount of P30,000 as attorney’s fees and litigation expenses.
Appellate Proceedings and Relief Sought
- The Court of Appeals, in CA G.R. CV No. 56109, rendered a Decision dated September 8, 2000 affirming the RTC judgment.
- Petitioners filed a motion for reconsideration before the Court of Appeals, which was denied in a Resolution dated November 20, 2000.
- Petitioners then filed a Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Civil Procedure, as amended, seeking review of the Court of Appeals’ Decision and Resolution.
Issues Presented by Petitioners
- Petitioners principally contended that Lot No. 1580 belongs to them (as shown by TCT No. T-40624).
- Petitioners additionally contended that respondents’ claim is barred by prescription.
Standard and Scope of Review Under Rule 45 (Legal/Factual Limits)
- It is a settled principle that a petition for review on certiorari under Rule 45 raises only questions of law and generally does not permit reexamination of factual findings already passed upon by the Court of Appeals.
- The Supreme Court may review findings of fact when particular exceptions are present, including:
- (a) when factual findings of the Court of Appeals and those of the trial court are contradictory;
- (b) when the Court of Appeals’ inference is manifestly mistaken or absurd;
- (c) when the appellate judgment is premised on a misapprehension of the facts;
- (d) when the Court of Appeals failed to resolve relevant facts which, if properly considered, would justify modification or reversal of the appellate decision.
- The Court cited Fuentes v. Court of Appeals (G.R. No. 109849, February 29, 1997) and other authorities in support of these principles.
Application of the Standard to the Ownership Claim
- The question whether petitioners are the owners of Lot No. 1580 is essentially factual and requires weighing of evidence presented before the lower courts.
- Because the issue is factual in nature and the Court of Appeals already assessed the evidence (notably the resurvey conducted by Engr. Romulo Unciano and approved by the Bureau of Lands), the Supreme Cou