Facts:
1. The case involves a dispute over three parcels of land in Rio Chico, General Tinio, Nueva Ecija, which totaled an area of 27,076 square meters. The land is registered in Eufrocina Rivera’s name under three Original Certificates of Title (OCT Nos. P-27012, P-27013, and P-27014) and corresponding tax declarations.
2. Rivera claimed she acquired the lands through Free Patent Applications with the DENR-CENRO in Cabanatuan City, which led to the issuance of Torrens titles in her name.
3. Rivera discovered in June 2014 that Rolando Velasco had constructed a house on a portion (6,397 square meters) of her titled lands without her consent. Despite demands, Velasco refused to vacate the land; barangay mediation failed to resolve the dispute.
4. Velasco, in his defense, asserted ownership, claiming possession since 1995, and alleged Rivera’s fraudulent acquisition in her patent applications. He filed a Protest against Rivera before the DENR in September 2014.
5. The MTC ruled in favor of Rivera on July 6, 2015, ordering Velasco and those under him to vacate the land, pay monthly rent of PHP 5,000 from June 21, 2014, and reimburse legal costs.
6. Velasco appealed to the RTC, which affirmed the MTC’s decision on October 21, 2016. The RTC supported the jurisdiction of the MTC and validated Rivera’s title ownership against Velasco’s allegations.
7. Velasco’s appeal to the CA was successful; the CA overturned the RTC’s decision, stating ownership issues need resolution and cannot be decided in an ejectment case.
8. Rivera filed a Petition for Review with the Supreme Court, challenging the CA’s order dismissing her complaint for forcible entry.
Issues:
1. Whether the Court of Appeals erred in dismissing Rivera’s complaint for forcible entry due to the ownership issues intertwined with the case.
2. Whether Rivera had established prior physical possession and Velasco’s unlawful encroachment by stealth or strategy, essential for a forcible entry claim.
3. Whether handling the ownership dispute fell outside the purview of an ejectment complaint which deals strictly with physical possession issues.
Court’s Decision:
1. The Supreme Court reversed the CA’s decision, reinstating the MTC’s ruling in favor of Rivera with modifications, including a 6% annual interest on the monetary award from the finality of judgment.
2. The Court emphasized ejectment proceedings are designed to protect possession rights against unlawful encroachments, not ownership disputes, which can be addressed separately.
3. The ruling established that a Torrens title is immune from collateral attack and cannot be questioned within the context of an ejectment suit.
4. The Court held that the factual findings confirmed Rivera’s prior possession and her compliant filing timeline, legitimizing her forcible entry suit.
Doctrine:
1. Torrens certificates of title cannot be collaterally attacked and are indefeasible except in direct proceedings.
2. For ejectment: The primary issue is the right to possession (possession de facto), not ownership (possession de jure), and the relief is meant to maintain public order by settling possession disputes expeditiously.
3. Forcible entry requires the plaintiff to prove prior possession and unlawful deprivation through force, intimidation, threat, strategy, or stealth.
Class Notes:
– Summary ejectment proceedings (unlawful detainer/forcible entry) quickly resolve possession issues, unlinked to ownership.
– Torrens title principle – Immunity from collateral attacks.
– Physical possession is the key in ejectment, not ownership claims.
– Relevant statute: Section 48 of P.D. No. 1529 prohibits collateral attacks on a Torrens title.
– Doctrine from Co v. Court of Appeals: Distinction between direct and collateral attacks on title.
Historical Background:
– The case underscores the legal framework surrounding land disputes in the Philippines, particularly issues of possession versus ownership under the Torrens system, designed to provide certainty of title and secure jurisdiction for possession disputes. This reflects an ongoing emphasis within Philippine jurisprudence on maintaining public order through clear avenues for resolving intrapersonal property conflicts.
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