Moldex Realty, Inc. and Rey Ignacio Diaz vs. Spouses Ernesto V. Yu and Elsie Ong Yu
**Facts:**
1. **Background Information:**
– Spouses Ernesto and Elsie Yu (Spouses Yu) owned two parcels of land in Dasmarinas, Cavite, registered under TCT Nos. T-280169 and T-280170.
– Moldex Realty, Inc. (Moldex) owned an adjacent parcel of land, registered under TCT No. T-317603.
2. **Filing of Complaint:**
– Spouses Yu filed a complaint for prohibitory injunction, temporary restraining order, removal of perimeter fence, and damages against Moldex and its Executive Vice President, Rey Ignacio Diaz.
– The complaint asserted that Moldex had encroached upon 3,159 sq.m of Lot 3869-N-1-A by constructing a perimeter fence on their property.
3. **Joint Motion for Survey:**
– Both parties filed a joint motion for the RTC to direct the DENR to conduct a land survey.
– The RTC issued an order for Engr. Danilo A. Arellano to conduct the survey.
4. **Initial RTC Decision (1999):**
– RTC dismissed the Yu’s complaint for lack of merit, concluding no encroachment based on technical descriptions of titles.
– Spouses Yu appealed the dismissal.
5. **CA Remand (2002):**
– Court of Appeals reversed RTC’s decision and remanded for further hearing, citing discrepancies in boundary descriptions.
6. **Subsequent RTC Decision (2016):**
– After additional proceedings, the RTC again dismissed the complaint, finding no boundary overlap.
7. **Second CA Decision (2018):**
– CA reversed RTC’s decision, ordering Moldex to remove constructions and pay damages, relying on expert testimony contradicting previous findings.
8. **Motion for Reconsideration:**
– Moldex’s motion for reconsideration was denied by the CA.
9. **Petition for Review:**
– Moldex filed a Petition for Review on Certiorari to the Supreme Court challenging the CA’s findings.
**Issues:**
1. **Collateral Attack on Title:**
– Whether the claim of encroachment by Spouses Yu constitutes a collateral attack on Moldex’s title.
2. **Right to Prohibitory Injunction:**
– Whether Spouses Yu are entitled to a prohibitory injunction given the title’s supposed technical inconsistencies.
3. **Reliance on Surveys and Expert Testimonies:**
– Whether the CA erred in relying on the testimony of Engr. Arellano over the survey and title descriptions.
4. **Award of Damages:**
– Whether the awards for moral damages and attorney’s fees to Spouses Yu are justified.
**Court’s Decision:**
1. **Collateral Attack on Title:**
– Court observed that boundary disputes leading to relief sought by Spouses Yu would alter the title, making it a prohibited collateral attack. The proper course is a direct proceeding specifically to address title modifications.
2. **Right to Prohibitory Injunction:**
– Court found that Spouses Yu failed to establish unequivocal right to the disputed land as required for injunction because of noted discrepancies in their titles’ technical descriptions.
– Emphasized principle: injunctions require clarity in the complainant’s title or right, which was absent here due to the incongruities in location vis-à-vis technical descriptions.
3. **Reliance on Surveys and Expert Testimonies:**
– Affirmed importance of technical descriptions in Torrens titles, assessing Engr. Arellano’s testimony insufficient against documented title descriptions.
– Criticized the CA for directing the application of surveying principles contradictory to the titles’ technical descriptions.
4. **Award of Damages:**
– Agreed with RTC that both parties acted in good faith without sufficient evidence supporting claims for damages and attorney’s fees.
**Doctrine:**
– Torrens titles serve as the best evidence of land ownership, emphasizing the inviolability of technical descriptions over situational adjustments via surveying.
– Injunctions in property cases require the plaintiff’s title or right to be clear and unchallenged.
– Boundary disputes potentially altering a title need to be resolved via direct proceedings, not as incidents in other actions.
**Class Notes:**
– **Real Property Law:**
– **Torrens System:** Emphasizes indefeasibility and conclusiveness of Torrens titles.
– **Boundary Disputes:** Require direct actions, not collateral proceedings.
– **Technical Descriptions:** Essential in defining property boundaries.
– **Civil Procedure:**
– **Collateral Attack:** Prohibited on Torrens titles to preserve integrity and stability.
– **Injunctions:**
– Require clear proof of right or title by the plaintiff.
– Equity will not intervene if the plaintiff’s title is doubtful.
**Historical Background:**
– The case is contextualized within Friar Lands’ historical subdivisions and disparities in map accuracy which often lead to modern legal disputes over property boundaries.
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