G.R. No. 76031 - Semira vs. Court of Appeals

Juana Gutierrez owned a parcel of land designated as Lot 4221 in Sto. Niño, Taysan, Batangas.
On January 4, 1961, she sold Lot 4221 to Buenaventura An for P850.00, specifying an area of 822.5 square meters and detailing its boundaries.
Buenaventura An entered the property and respected the stated boundaries.
An subsequently acquired two additional parcels of land, including Lot 4215, from the Hornilla spouses in 1964.
On October 18, 1972, An sold Lot 4221 to his nephew, Cipriano Ramirez, for P2,500.00, with a description that included the same boundaries but changed the eastern boundary from Juana Gutierrez to Buenaventura An.

Cipriano Ramirez occupied Lot 4221 and later applied for a new tax declaration, which was denied due to an existing mortgage by Buenaventura An.
On March 12, 1979, Ramirez sold Lot 4221 to Miguel Semira for P20,000.00, stating an area of 2,200 square meters, which was confirmed by a 1974 cadastral survey.
Semira began construction on the property but was met with a forcible entry complaint from An on April 18, 1979, claiming that Semira was occupying an excess area that belonged to Lot 4215.

The Municipal Circuit Trial Court (MCTC) initially dismissed the case for lack of jurisdiction, stating that ownership issues could not be resolved without determining prior physical possession.
Following the enactment of B.P. Blg. 129, the MCTC modified its ruling and recognized Semira as the rightful possessor of the disputed area.
An appealed to the Regional Trial Court (RTC), which reversed the MCTC's decision, asserting that prior possession could be determined independently of ownership.

Semira's appeal to the Court of Appeals was unsuccessful, as the appellate court upheld the RTC's ruling.
Semira contended that the Court of Appeals erred in affirming his ejectment without clear proof of An's prior possession and in failing to recognize the intertwined nature of possession and ownership.

The Supreme Court agreed with Semira, stating that the issue of possession could not be resolved without addressing ownership.
Both parties claimed possession based on their respective deeds of sale, making the determination of ownership crucial to resolving the possession dispute.

The Court noted that Lot 4221 was sold for a lump sum, and the boundaries specified in the sale documents determined the extent of the sale, not the stated area.
According to Article 1542 of the Civil Code, when land is sold for a lump sum, the vendor is obligated to deliver all land w...continue reading