Primary Holding

A boundary dispute cannot be settled summarily through an action for forcible entry under Rule 70 of the Rules of Court, as it involves issues of encroachment rather than mere possession.

Background

Rosario Monasterial filed a case for forcible entry against Engr. Vivencio Fontamillas and Kingsville Construction and Development Corporation regarding a property dispute. She presented sketch plans and a deed of sale to support her claim, while Kingsville presented a Torrens title.

Facts

• 1. Monasterial filed a forcible entry case claiming possession of a property
• 2. She presented sketch plans dated August 13, 2015 and February 10, 2017
• 3. She also presented a Deed of Absolute Sale
• 4. Kingsville Construction presented Transfer Certificate of Title No. 334180
• 5. The case involved a boundary dispute between the parties

Arguments of the Petitioners

• 1. Claims the case falls under exceptions to Rule 45
• 2. Cites Esperal v. Trompeta-Esperal case as basis
• 3. Argues she clearly identified the subject property
• 4. Claims prior physical possession of the property
• 5. Contends forcible entry is the proper proceeding

Arguments of the Respondents

• 1. Presented Torrens title with technical descriptions
• 2. Argued case involves boundary dispute beyond MTCC jurisdiction
• 3. Maintained proper remedy is accion reivindicatoria

Issues

• 1. Whether the case falls under exceptions to Rule 45
• 2. Whether petitioner proved prior physical possession
• 3. Whether forcible entry is the proper remedy for a boundary dispute

Ruling

• 1. Petition DENIED for failure to show CA committed reversible error
• 2. Reliance on Esperal case is misplaced as factual findings of MTCC, RTC, and CA are consistent
• 3. Sketch plans without approval from Land Management Bureau have no evidentiary value
• 4. Boundary disputes cannot be settled through forcible entry cases
• 5. Torrens title prevails over unregistered claims

Doctrines

• 1. Rule on factual findings of trial courts being accorded highest respect
• 2. Principle of indefeasibility of Torrens titles
• 3. Doctrine on proper jurisdiction over boundary disputes
• 4. Rule on requirements for forcible entry cases

Key Excerpts

• 1. "The fundamental purpose of the land registration law is to finally settle title to real property. Consequently, once the title is registered under the said law, owners can rest secure on their ownership and possession."
• 2. "It has long been held that unless a survey plan is duly approved by the Director of Lands, the same is of dubious value and is not acceptable as evidence."

Precedents Cited

• 1. Esperal v. Trompeta-Esperal (G.R. No. 229076, September 16, 2020) - distinguished from present case
• 2. Republic Cement Corporation v. Court of Appeals (275 Phil. 812, 1991) - on value of unapproved survey plans
• 3. Republic v. Heirs of Sta. Ana (G.R. No. 233578, March 15, 2021) - on indefeasibility of Torrens titles
• 4. Martinez v. Heirs of Lim (G.R. No. 234655, September 11, 2019) - on boundary disputes
• 5. Manalang v. Bacani (750 Phil. 25, 2015) - on nature of forcible entry

Statutory and Constitutional Provisions

• 1. Article 434 of the New Civil Code - on requirements in action to recover property
• 2. Rule 45 of the Rules of Court - on petition for review on certiorari
• 3. Rule 70 of the Rules of Court - on forcible entry proceedings