Case Summary (G.R. No. 198356)
Key Dates
1979 – Issuance of Torrens Certificate of Title to Spouses Supapo
1992 – Discovery of unauthorized construction and occupation by respondents; issuance of Katibayan Upang Makadulog sa Hukuman
1996 – RTC conviction of respondents for violation of PD No. 772 with civil liability to vacate
1999 – Final dismissal of criminal case upon repeal of PD No. 772 by RA No. 8368
2008 – Filing of complaint for accion publiciana in Metropolitan Trial Court (MeTC), Caloocan
2011 – Court of Appeals decision dismissing accion publiciana (CA-G.R. SP No. 111674)
Applicable Law
1987 Philippine Constitution (frame of judicial authority)
Presidential Decree No. 772 (Anti-Squatting Law, repealed by RA 8368)
Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980) as amended by RA 7691 (jurisdictional thresholds for MeTC)
Civil Code Articles 537, 555, 1126 (prescription and adverse possession)
PD No. 1529 Section 47 (Torrens system imprescriptibility)
Rules of Court, Rule 45 (certiorari), Rule 65 (certiorari for interlocutory orders), Rule 39 Section 47 (res judicata)
Factual Antecedents
The Spouses Supapo hold a Torrens title over the subject lot in Novaliches, Quezon City, with assessed value ₱39,980.00. They visited periodically but did not reside there. In 1992 they observed two houses erected without their permission, one occupied by Spouses de Jesus and the other by Macario Bernardo. Attempts at amicable settlement before the Lupong Tagapamayapa failed, leading to issuance of a certificate to file action. A criminal case under PD No. 772 followed, resulting in respondent conviction and order to vacate. After repeal of PD No. 772, the criminal and derivative civil liabilities were dismissed.
Procedural History
- Spouses Supapo filed a complaint for accion publiciana in MeTC Caloocan (2008).
- Respondents raised affirmative defenses—pendency of another action, prescription, and res judicata—through motion for preliminary hearing, which MeTC denied.
- Respondents petitioned for certiorari to RTC, which granted on grounds of prescription and exclusive RTC jurisdiction, dismissing the MeTC case.
- Spouses Supapo’s motion for reconsideration denied; they appealed to the Court of Appeals.
- CA affirmed RTC: accion publiciana should have been filed in RTC and was time-barred.
- Petition for review on certiorari (Rule 45) brought to Supreme Court.
Issues Presented
- Did the MeTC properly acquire jurisdiction over the accion publiciana?
- Has the Spouses Supapo’s cause of action prescribed?
- Is the accion publiciana barred by res judicata?
Jurisdiction of the MeTC
Under Batas Pambansa Blg. 129 as amended by RA 7691, MeTCs have exclusive original jurisdiction over real property actions where the assessed value does not exceed ₱50,000 in Metro Manila. The Spouses Supapo alleged and proved an assessed value of ₱39,980.00 by tax declaration. Respondents did not contest the declaration’s authenticity. Hence, jurisdiction properly lies with MeTC, not the RTC.
Non-prescription of the Action
Article 555(4) of the Civil Code provides that the real right of possession is not lost until after ten years of adverse possession. However, under PD No. 1529 Sec. 47 and Civil Code Art. 1126, registered lands under the Torrens system are imprescriptible in derogation of the owner’s title. Petitioners’ Torrens title is genuine and unchallenged; no contrary title was recorded by respondents. The right to possess and eject trespassers is an attribute of Torrens ownership and cannot be lost by prescription or adverse possession. Allegations of laches are evidentiary and unsubstantiated in the record. Thus, the cause of action remains timely.
Inapplicability of Res Judicata
Res judicata requires iden
Case Syllabus (G.R. No. 198356)
Factual Antecedents
- Petitioners (Spouses Supapo) hold Transfer Certificate of Title No. C-28441 over Lot 40, Block 5 in Novaliches, Quezon City, with assessed value ₱39,980.00.
- They did not reside on the lot nor employ an overseer, but visited at least twice a year.
- In 1992 they discovered two houses erected without their consent—one occupied by Spouses de Jesus, the other by Macario Bernardo.
- They demanded surrender before the Lupong Tagapamayapa, which on November 25, 1992 issued a “Katibayan Upang Makadulog sa Hukuman” certifying failure to settle amicably.
Criminal Proceedings Under PD No. 772
- Spouses Supapo filed Criminal Case No. C-45610 in RTC Branch 131, Caloocan City, for violation of Presidential Decree No. 772 (Anti-Squatting Law).
- The trial court convicted respondents, fined ₱1,000 each, and ordered them to vacate the premises.
- Respondents appealed to the Court of Appeals (CA-G.R. No. 19538).
- While appeal was pending, RA 8368 repealed PD 772; the criminal case was dismissed and became final on April 30, 1999.
- Spouses Supapo moved to execute civil liability (vacation of lot); RTC granted a writ of execution and denied respondents’ motions to quash or reconsider.
- Respondents filed certiorari (CA-G.R. SP No. 78649); the CA granted it, held repeal extinguished both criminal and civil liabilities, and permanently enjoined execution—while noting that landowners still retain remedy by filing proper civil action for recovery of possession.
Action for Accion Publiciana
- On March 7, 2008, Spouses Supapo filed Civil Case No. 08-29245 for accion publiciana in MeTC Branch 52, Caloocan City, seeking to recover possession of the subject lot.
- Respondents answered and moved to set affirmative defenses for preliminary hearing, arguing (a) another action