A Petition for Review on Certiorari under Rule 45 of the Rules of Court is generally confined to questions of law, and factual findings of the trial court that are affirmed by the Court of Appeals are binding upon the Supreme Court unless specific exceptions apply; in actions to recover property, the plaintiff bears the burden of clearly identifying the property claimed and must rely on the strength of their own title, with unapproved survey plans being insufficient to establish property identity against a registered Torrens title, and an action for forcible entry is not the appropriate remedy for resolving what is essentially a boundary dispute.

The case originated from a possessory dispute where petitioner Rosario N. Monasterial filed an action for forcible entry against respondents Engr. Vivencio Fontamillas and Kingsville Construction and Development Corporation. Monasterial alleged that respondents unlawfully deprived her of physical possession of a portion of land she claimed, prompting her to seek judicial remedy to recover said possession. The core of the dispute involved Monasterial's claim of prior possession over an unregistered property versus Kingsville's assertion of ownership based on a Torrens title.

• Petitioner Rosario N. Monasterial (Rosario) filed a forcible entry case against respondents Engr. Vivencio Fontamillas and Kingsville Construction and Development Corporation (Kingsville).
• Rosario claimed prior physical possession of a certain property which she alleged was unregistered.
• To support her claim and identify the property, Rosario submitted a Sketch Plan dated August 13, 2015, and another Sketch Plan dated February 10, 2017.
• These sketch plans submitted by Rosario lacked the approval of the Land Management Bureau under the Department of Environment and Natural Resources.
• Rosario's claim was partly based on a Deed of Absolute Sale.
• Respondent Kingsville presented Transfer Certificate of Title (TCT) No. 334180, which contained technical descriptions of its property defined by metes and bounds.
• The Municipal Trial Court in Cities (MTCC), the Regional Trial Court (RTC), and the Court of Appeals (CA) all consistently found that Rosario failed to establish her case for forcible entry and failed to prove her prior physical possession of the subject property.

• The Petition for Review on Certiorari falls under the recognized exceptions to Rule 45 of the Rules of Court, specifically citing Esperal v. Trompeta-Esperal, which petitioner argued would warrant a review of the lower courts' factual conclusions.
• Petitioner asserted that she had clearly identified the subject property and had successfully proven her prior physical possession of the same.
• Petitioner contended that the Court of Appeals erred in holding that an ejectment case for forcible entry was not the proper legal proceeding for her claim and that the appropriate remedy should be an accion reivindicatoria.

• Petitioner failed to clearly and sufficiently identify the property she was claiming, a prerequisite in actions to recover possession or ownership.
• Petitioner failed to prove her alleged prior physical possession of the subject property.
• The sketch plans submitted by the petitioner were unreliable and lacked probative value as they were not approved by the appropriate government authority (Land Management Bureau).
• Respondent Kingsville Construction and Development Corporation possessed a valid Torrens title (TCT No. 334180) that clearly described its property, which should be accorded more weight than petitioner's unsubstantiated claims over an unregistered property.
• The dispute essentially involved a boundary issue, which is not within the purview of a summary ejectment suit for forcible entry and should be litigated in a different, more appropriate action.

• Whether the Court of Appeals committed a reversible error in affirming the consistent findings of the MTCC and RTC that petitioner Rosario N. Monasterial failed to establish her case for forcible entry.
• Whether petitioner Rosario N. Monasterial sufficiently identified the subject property and proved her prior physical possession thereof as required in a forcible entry case.
• Whether an action for forcible entry under Rule 70 of the Rules of Court is the proper remedy when the issue involves a boundary dispute, and the plaintiff claims an unregistered property against a defendant holding a Torrens title.

• The Supreme Court DENIED the Petition for Review on Certiorari filed by Rosario N. Monasterial and AFFIRMED the assailed Decision and Resolution of the Court of Appeals.
• The Court found petitioner's reliance on Esperal v. Trompeta-Esperal to be misplaced because, unlike in Esperal where there were conflicting factual findings between the RTC and CA, the findings of the MTCC, RTC, and CA in the instant case were consistent in concluding that petitioner failed to establish her case for forcible entry and prove prior physical possession.
• The Court reiterated the principle that factual findings of trial courts, especially when affirmed by the appellate court, are accorded the highest degree of respect and are generally binding, and petitioner failed to show any clear disregard of evidence or abuse, arbitrariness, or capriciousness by the lower courts.
• The Court upheld the CA's finding that petitioner failed to clearly identify the property she claimed, as mandated by Article 434 of the New Civil Code. The property was unregistered, and the sketch plans she submitted lacked approval from the Land Management Bureau, rendering them of dubious evidentiary value.
• In contrast, respondent Kingsville presented a Torrens title (TCT No. 334180) with technical descriptions. The Court emphasized the fundamental purpose of the land registration law to settle titles and allow registered owners to rest secure on their ownership and possession.
• The Court concurred with the CA that the issue raised by petitioner essentially involved a boundary dispute, which is not within the jurisdiction of the MTCC in an ejectment suit. A boundary dispute cannot be settled summarily through an action for forcible entry under Rule 70 of the Rules of Court, as it concerns encroachment rather than the simple fact of prior physical possession.

• Rule 45 Petitions Limited to Questions of Law — A petition for review on certiorari filed with the Supreme Court under Rule 45 of the Rules of Court is generally restricted to resolving questions of law, and factual findings of lower courts are typically not disturbed unless specific, recognized exceptions are present. This was applied as the Court found no exceptional circumstance to warrant a factual review, as petitioner's arguments primarily challenged the uniform factual findings of the lower courts.
• Binding Effect of Factual Findings of Lower Courts — Factual findings made by a trial court, particularly when affirmed by the Court of Appeals, are accorded the highest degree of respect and are generally considered binding and conclusive upon the Supreme Court, absent any clear showing of abuse, arbitrariness, capriciousness, or a palpable disregard of the evidence. This doctrine was applied to uphold the consistent findings of the MTCC, RTC, and CA that petitioner failed to prove her case for forcible entry.
• Requirement of Property Identification in Recovery Actions (Article 434, New Civil Code) — Article 434 of the New Civil Code provides that in an action to recover property, the property must be identified, and the plaintiff must rely on the strength of his title and not on the weakness of the defendant's claim. This was applied because the petitioner failed to clearly identify the unregistered property she claimed, using unapproved sketch plans, which was fatal to her cause of action for recovery.
• Probative Value of Unapproved Survey Plans — Survey plans that have not been duly approved by the Director of Lands (now the Land Management Bureau of the DENR) are considered of dubious value and are generally not acceptable as competent evidence to prove the identity or boundaries of a parcel of land. This doctrine was applied to the sketch plans submitted by the petitioner, which lacked the necessary government approval and thus could not be given significant weight or credence.
• Indefeasibility and Security of Torrens Title — The Torrens system of land registration aims to finally settle title to real property, allowing registered owners to rest secure in their ownership and possession; a Torrens title is generally considered indefeasible and proceedings leading to its issuance are presumed regular. This was applied to give more credence to respondent Kingsville's TCT No. 334180 over petitioner's claims based on a deed of sale for an unregistered property and unapproved plans.
• Forcible Entry Jurisdiction and Scope (Rule 70, Rules of Court) — An action for forcible entry under Rule 70 is a summary proceeding designed to provide an expeditious means to restore physical possession to one who has been illegally deprived thereof. It is not the proper remedy for resolving complex issues of ownership or boundary disputes, the latter involving questions of encroachment and precise property limits, which are outside the MTCC's limited jurisdiction in an ejectment suit. This was applied to affirm the CA's finding that the petitioner's case, being a boundary dispute, was not appropriate for a forcible entry action.

• "[I]t 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."
• "[T]he 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. The Court also held that proceedings for land registration that led to the issuance of a registration decree ... were presumed to have regularly and properly been conducted. To overturn this legal presumption carelessly, will not only endanger judicial stability, but also violate the underlying principle of the Torrens system. Indeed, to do so would reduce the vaunted legal indefeasibility of Torrens titles to meaningless verbiage."

• Esperal v. Trompeta-Esperal, G.R. No. 229076, September 16, 2020 — This case was cited by the petitioner to argue that her petition fell under exceptions allowing factual review by the Supreme Court. The Court distinguished it, noting that Esperal involved conflicting factual findings between the RTC and CA, unlike the present case where the MTCC, RTC, and CA had consistent findings against the petitioner.
• Heirs of Villanueva v. Heirs of Syquia Mendoza, 810 Phil. 172 (2017) (citing Uyboco v. People, 749 Phil. 987 (2014)) — This case was cited to reinforce the well-settled rule that factual findings of the trial court are accorded the highest degree of respect by an appellate tribunal and, absent clear disregard of evidence or abuse, arbitrariness, or capriciousness, such findings are binding and conclusive.
• Republic Cement Corporation v. Court of Appeals, 275 Phil. 812 (1991) — This case was referenced to support the Court's position that unapproved survey plans are of dubious value and are not acceptable as evidence for identifying property.
• Republic of the Philippines v. Heirs of Sta. Ana, G.R. No. 233578, March 15, 2021 (citing Tichangco v. Enriquez, 477 Phil. 379 (2004)) — This case was cited to underscore the fundamental purpose of the land registration law, the security afforded by a Torrens title, and the presumption of regularity in land registration proceedings.
• Martinez v. Heirs of Lim, G.R. No. 234655, September 11, 2019 — This case was cited to reiterate the doctrine that a boundary dispute cannot be settled summarily through an action for forcible entry under Rule 70 of the Rules of Court.
• Manalang v. Bacani, 750 Phil. 25 (2015) — This case was referenced to explain that a boundary dispute is not primarily about possession but about encroachment (i.e., whether the property claimed by the defendant forms part of the plaintiff's property), distinguishing it from forcible entry where the core issue is prior de facto possession.

• Rules of Court, Rule 45, Section 1 — This provision, which states that a Petition for Review on Certiorari shall raise only questions of law, was invoked to emphasize the general limitation on the Supreme Court's review powers in such petitions and was a basis for not re-evaluating the consistent factual findings of the lower courts.
• New Civil Code, Article 434 — This article, which requires that in an action to recover property, the property must be identified and the plaintiff must rely on the strength of their own title, was applied by the Court to highlight the petitioner's failure to clearly identify the unregistered property she claimed.
• Rules of Court, Rule 70 — This rule, which governs actions for forcible entry and unlawful detainer (ejectment suits), was cited to explain that forcible entry is a summary proceeding focused on prior physical possession and is not the appropriate mechanism for resolving boundary disputes, which are outside the limited jurisdiction of the MTCC in such cases.