Case Summary (G.R. No. 203918)
Background of the Case
The matter arose from a dispute over a 1,722-square meter agricultural land (riceland) located in Borongan, Eastern Samar. The Spouses Cantara claimed ownership based on a purchase from a prior owner in 1993. They asserted that they were the rightful possessors of the land, cultivating it through tenants. In December 2007, Sps. Cayago allegedly forcibly entered the property, cleared it, and planted rice, leading to Sps. Cantara filing a complaint for forcible entry against them in January 2008.
Proceedings in the Municipal Trial Court (MTC)
The MTC dismissed the complaint on February 27, 2009, asserting Sps. Cayago had sufficiently demonstrated ownership and prior possession backed by a certificate of title and tax declarations. The court determined that Sps. Cayago underwent proper administrative processes to secure legal ownership of the land.
Regional Trial Court (RTC) Ruling
Sps. Cantara appealed the MTC’s decision to the RTC, which reversed it on August 14, 2009. The RTC concluded that Sps. Cantara had superior claim due to the notarized Deed of Sale from Asteria, evidencing their possession since 1993. It criticized the MTC for relying too heavily on the documentation presented by Sps. Cayago without a formal offer during the trial.
Motion for Reconsideration and Court of Appeals
Following the RTC's decision, Sps. Cayago filed a motion for reconsideration, which was denied. They then filed a petition for review with the Court of Appeals, requesting an extension to file the petition, which they ultimately filed on August 16, 2010. This petition was dismissed by the CA on April 14, 2011, due to late filing and procedural irregularities, including deficiencies in the notarial certificate accompanying their petition.
Supreme Court Review
Sps. Cayago's appeal was brought before the Supreme Court, focusing on whether the CA erred in dismissing their petition for being late. The Court held that procedural rules should not obstruct the pursuit of substantial justice. It found th
...continue readingCase Syllabus (G.R. No. 203918)
Background of the Case
- The case originated from a complaint for forcible entry with preliminary mandatory injunction and damages filed by respondents Evelito and Soledad Cantara (Sps. Cantara) against petitioners Amador C. Cayago, Jr. and Ermalinda B. Cayago (Sps. Cayago) on January 17, 2008.
- Sps. Cantara claimed to be the rightful owners and actual possessors of a 1,722-square meter riceland in Borongan, Eastern Samar, covered by Tax Declaration No. 10520 in the name of Asteria Rubico.
- The land was purchased by Sps. Cantara from Asteria in 1993 through a Deed of Absolute Sale and has been cultivated by their tenants, Pedro and Leonila Segovia.
- In December 2007, Sps. Cayago entered the land without consent and began cultivating it, prompting Sps. Cantara to file a complaint after their demands for vacating the land were ignored.
Defenses of the Petitioners
- Sps. Cayago contended that they were the true owners of the subject land, claiming possession since 1948, as substantiated by a Tax Declaration in the name of Sabina Cayago and an Original Certificate of Title issued in 2006 to the heirs of Amador P. Cayago, Sr.
- They argued that the Deed of Sale presented by Sps. Cantara was not registered, thus rendering it invalid against their claims.
Proceedings in the Municipal Trial Court (MTC)
- During the preliminary conference on March 31, 2008, both parties agreed to condu