Case Summary (G.R. No. 158002)
Complaint Details
On December 1, 1997, the petitioners filed a Complaint for Damages with an accompanying Prayer for Preliminary Injunction, claiming ownership of a 50,000 square meter piece of land covered by Original Certificate of Title (OCT) No. P-691. They alleged that the respondents, while constructing a barbed-wire fence on their adjacent property, encroached on the petitioners’ land, resulted in the destruction of their farmhouse, and cut down bamboos and trees. The complaint further indicated that the respondents obstructed the petitioners' access to their property and threatened to cause further damage using a bulldozer.
Respondents' Answer and Counterclaim
In their Answer filed on June 16, 1998, the respondents contended ownership of the disputed land based on Transfer Certificate of Title (TCT) No. 236044. They claimed their actions were legitimate exercises of property rights and alleged that the petitioners could not prove their claims regarding property boundaries. The respondents also filed a counterclaim for damages against the petitioners.
Relocation Survey Findings
A relocation survey was conducted on September 18, 1998, with a team appointed by the court, which concluded that the petitioners’ title overlapped with the respondents' title but did not reflect the actual area occupied by the petitioners. The survey findings indicated that the petitioners' property was erroneously described and connected to another titled parcel (H-164008), suggesting a defect in the petitioners’ title.
Trial Court Decision
Based on the survey report and the respondents' motion to dismiss, the trial court dismissed the petitioners' complaint on December 22, 1999. The petitioners' subsequent motion for reconsideration was denied on July 11, 2000, allowing them to pursue an appropriate action for correcting the technical description of their property.
Court of Appeals Ruling
The Court of Appeals, affirming the lower court's decision on November 29, 2002, upheld that the relocation survey's findings must be respected. The appellate court addressed the absence of objections from the petitioners regarding the survey team’s composition and stated that their claims did not provide a legal basis for damages.
Grounds for Petitioners' Review
In their petition, the petitioners articulated several grounds for seeking a review, asserting errors in the appellate court's ruling. They highlighted their ownership based on the registered title, contending that the relocation survey should not undermine their ownership rights. They also cited the alleged defectiveness of the respondents' title and claims of inadequate legal representation, which they argued denied them due process.
Respondents' Defense
The respondents countered that the petitioners were estopped from contesting the survey report's validity, emphasizing that the report was conducted by competent professionals and that the petitioners actively participated in the process. They argued that any oversight by the petitioners’ former counsel did not excuse the lack of actionable evidence against their title.
Legal Implications of Title Ownership
The primary issue involved whether the subject property was part of the
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Case Information
- Court: Supreme Court of the Philippines
- Division: Second Division
- G.R. No.: 158002
- Date: February 28, 2005
- Petitioners: Spouses Aurora N. De Pedro and Elpidio De Pedro
- Respondents: Romasan Development Corporation and Manuel Ko
Background of the Case
- The petitioners filed a complaint for damages and a prayer for preliminary injunction against the respondents on December 1, 1997.
- Petitioners claimed ownership of a 50,000 square meter parcel of land in Barangay San Isidro, Antipolo, Rizal, covered by Original Certificate of Title No. P-691.
- They alleged that the respondents began constructing a barbed-wire fence on an adjacent property, resulting in the destruction of their farmhouse and the cutting of trees.
- The respondents contested this claim, asserting ownership of the adjacent property via Transfer Certificate of Title No. 236044.
Proceedings in the Trial Court
- The respondents filed an answer asserting their ownership and a counterclaim for damages.
- The trial court ordered a relocation survey to determine the property boundaries on September 18, 1998.
- A survey team found that the petitioners' title overlapped with the respondents' title but indicated that the land occupied by the petitioners belonged to a different title (H-164008).
Findings of the Survey Team
- The survey team consisted of representatives from both parties and the DENR.
- The January 30, 1999 report indicated:
- The overlapping of titles was due to double issuance of title for H-162341.
- The petitioners' actual occupation was on Lot 10454/H-164008, not the area described in their title.
- The report indicated that correcting the technical desc