Case Summary (G.R. No. 242837)
Applicable Law
This decision is based on the 1987 Philippine Constitution, including relevant procedural laws as per Rule 70 of the Rules of Court, which pertains to actions for forcible entry and unlawful detainer.
Factual Background
Eufrocina Rivera claims ownership of three parcels of land registered under her name through Original Certificates of Title (OCT) and declared for taxation purposes. She asserts her prior possession beginning in 1992 and alleges that, on June 21, 2014, she discovered Rolando Velasco occupying part of her land (6,397 square meters) without her permission. Velasco contended that he was the rightful owner after occupying the property since 1995 and filed a protest against Rivera before the Department of Environment and Natural Resources (DENR).
Municipal Trial Court (MTC) Ruling
The MTC ruled in favor of Rivera, confirming her prior possession of the land based on evidence, including a Barangay Certification and a CENRO Report. The MTC noted that Velasco's defense asserting fraud in Rivera's acquisition of her title was an impermissible collateral attack on Torrens titles. Rivera was granted possession and ordered to evict Velasco, pay rentals, and award attorney's fees.
Regional Trial Court (RTC) Ruling
Velasco appealed the MTC's decision, claiming the absence of jurisdiction and elements necessary for forcible entry. However, the RTC affirmed the MTC's ruling, emphasizing that Rivera had established her right to possess the property and that any claims of fraud lacked substantive evidence.
Court of Appeals (CA) Ruling
The CA reversed the RTC's decision, asserting that the matter concerns a complex ownership issue that necessitates a civil action for reconveyance rather than simple forcible entry. The CA held that the existence of pending protests and claims against Rivera required the controversy to be fully resolved outside the ejectment context.
Supreme Court's Decision
The Supreme Court granted Rivera's petition, reinstating the MTC's ruling. It clarified that the primary objective in forcible entry suits is to restore physical possession to the party unlawfully deprived thereof, independent of any ownership disputes. The Court noted that Velasco's claims attacking Rivera’s titles were indeed collateral, thus impermissible in this summary p
...continue readingCase Syllabus (G.R. No. 242837)
Case Background
- This case revolves around a Petition for Review on Certiorari filed by Eufrocina Rivera (petitioner) against Rolando G. Velasco (respondent).
- The petition challenges the Decision dated February 15, 2018, and Resolution dated September 17, 2018, of the Court of Appeals (CA) in CAA-G.R. SP No. 151231.
- The CA reversed the previous rulings made by the Regional Trial Court (RTC) and the Municipal Trial Court (MTC), which had favored the petitioner in a case of forcible entry concerning three parcels of land in Rio Chico, General Tinio, Nueva Ecija.
Facts of the Case
- The subject properties, totaling approximately 27,076 square meters, are registered in the name of the petitioner under Original Certificates of Title (OCT) Nos. P-27012, P-27013, and P-27014.
- Petitioner claims she acquired these properties through Free Patent Applications filed with the Community Environment and Natural Resources Office (CENRO) of the Department of Environment and Natural Resources (DENR).
- On June 21, 2014, petitioner discovered that the respondent unlawfully occupied a portion of her land (6,397 square meters) by constructing a house without her consent.
- Petitioner filed a complaint for forcible entry on October 21, 2014, after allegedly exhausting all barangay-level settlement options.
Respondent's Position
- Respondent countered that he was the lawful owner of the disputed portion of the property, having occupied it since 1995.
- He filed a Protest against the petitioner before the DENR, claiming