Case Summary (G.R. No. 170096-97)
Factual Background
Respondent Iluminada Cruz initiated two ejectment actions against the Santos petitioners in the Metropolitan Trial Court (MTC), claiming that they had occupied her property without consent and had constructed structures thereon. Santos and Wong acknowledged Cruz's ownership, yet claimed to have purchased different portions of the land based on documents dating back to 1976 and 1978.
Procedural History
On February 4, 2005, the MTC dismissed Cruz's ejectment cases on the grounds that she failed to prove her claims by a preponderance of evidence. Dissatisfied with this ruling, Cruz appealed to the Regional Trial Court (RTC) of Malabon, which reversed the MTC decision on July 15, 2005. The RTC's decision mandated the Santos petitioners to vacate the premises and pay damages.
Legal Basis for the Petition
The Santos petitioners subsequently filed a petition for certiorari before the Supreme Court under Rule 65, alleging violations of their rights to procedural and substantive due process. However, the Court found numerous procedural infirmities in their petition, including failure to submit essential documents and certifications required by the Rules of Court.
Lack of Due Process Claims
The petitioners claimed the RTC acted contrary to due process but did not specifically articulate the acts or omissions that constituted the alleged violations. The Supreme Court indicated that the petition failed to demonstrate that the RTC's actions were arbitrary or capricious.
Examination of Substantive Claims
The petitioners relied on unregistered documents to support their ownership claims; however, the Court reaffirmed the principle that registered titles, such as those held by Cruz (TCT No. M-19968 and TCT No. 19973), are presumptively valid and indefeasible under the Torrens system. The Court emphasized that mere allegations of ownership based on unregistered deeds cannot override registered titles.
Procedural Requirements Not Met
The Supreme Court pointed out that the petitioners did not adhere to the requisite procedural rules for filing certiorari. They neglected to file a motion for reconsideration of the RTC's decision, which is generally a condition precedent before seeking certiorari relief. The Court reinforced the notion that certiorari serves as a remedy only when there is no adequate remedy available in the ordinary course of law.
Jurisdictional Issues
The petition
...continue readingCase Syllabus (G.R. No. 170096-97)
Case Background
- This case is a petition for certiorari filed under Rule 65 of the Rules of Court by petitioners Ricardo Santos and Paula Santos Wong against respondents Iluminada Cruz, represented by her attorney-in-fact Gloria Israel, and Judge Francisco Lindo of the Metropolitan Trial Court (METC) Branch 55, Malabon City.
- The petition challenges the Joint Decision dated July 15, 2005, of the Regional Trial Court, Branch 170, City of Malabon, which reversed the earlier decision made by the Metropolitan Trial Court.
Factual Context
- Respondent Iluminada Cruz owns a parcel of land covered by Transfer Certificates of Title (TCT) No. M-19968 and TCT No. 19973, which were partially occupied by the petitioners.
- Petitioner Ricardo Santos and his spouse admitted ownership of the land covered by TCT No. M-19968 but claimed they purchased 177 square meters through a Deed of Absolute Sale dated August 28, 1978.
- Petitioner Paula Wong acknowledged Cruz's ownership of the land under TCT No. 19973 and claimed that a portion measuring 142 square meters was sold to her deceased husband by Cruz under a Subdivision Agreement with Contract of Sale dated July 31, 1976.