There are 51 results on the current subject filter
Title | IDs & Reference #s | Summary | Background | Subject Matter |
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Pante vs. People (18th January 2021) |
AK603265 969 SCRA 243 , 894 Phil. 54 , G.R. No. 218969 |
The Supreme Court affirmed the conviction of Fernando Pante for theft. Pante was found guilty as a "finder in law" for failing to return money that was originally found by his co-accused minors. The Court held that even if Pante was not the original finder, his subsequent actions of appropriating the money and instructing the minors to keep it made him liable for theft under Article 308, par. 2(1) of the Revised Penal Code. | Dawson Word lost a bundle of money (US dollars and Philippine pesos). A minor, one of Pante's co-accused, found the money and shared it with Pante and another minor. Pante, the only adult, took a significant portion of the money and used it for personal expenses. He only returned a portion after police intervention. |
Property and Land Law |
PLDT vs. Citi Appliance M.C. Corporation (9th October 2019) |
AK339916 922 SCRA 518 , 864 Phil. 899 , G.R. No. 214546 |
This case involves a forcible entry action filed by Citi Appliance against PLDT regarding underground telephone lines discovered on Citi Appliance's property during construction. The Supreme Court ruled that the action for forcible entry had prescribed as it was filed more than one year after Citi Appliance discovered PLDT's encroachment, and that prior physical possession by Citi Appliance was not sufficiently proven. The Court clarified the reckoning point for the one-year prescriptive period in forcible entry cases based on stealth, emphasizing it starts from the discovery of the unlawful entry, not the last demand to vacate. | Citi Appliance, owner of a land in Cebu City, discovered underground telephone lines, cables, and manholes installed by PLDT while excavating for a parking lot for its planned commercial building. These installations were preventing Citi Appliance from fully utilizing its property. Citi Appliance sought to have PLDT remove these installations or pay for parking exemption fees, leading to a forcible entry case when PLDT refused. |
Property and Land Law |
Leviste Management System, Inc. vs. Legaspi Towers 200, Inc (4th April 2018) |
AK149294 829 Phil. 176 , 860 SCRA 355 , G.R. No. 199353 |
This case involves a dispute between Leviste Management System, Inc. (LEMANS) and Legaspi Towers 200, Inc. (Legaspi Towers) concerning the construction of an additional unit (Concession 4) by LEMANS on the roof deck of a condominium building owned and operated by Legaspi Towers. The Supreme Court ruled that the Condominium Act, Master Deed, and By-Laws govern the case, making Article 448 of the Civil Code on builders in good faith inapplicable, and upheld Legaspi Towers' right to abate the illegal construction at LEMANS' expense. | Legaspi Towers 200, Inc. owns and operates a condominium building. Leviste Management System, Inc. (LEMANS) owned Concession 3, a unit within the building. LEMANS sought to build Concession 4 on the roof deck above Concession 3. Legaspi Towers objected, arguing the construction was illegal as it violated the Master Deed and Condominium Act and was built without proper approvals. LEMANS claimed ownership of the airspace and good faith in the construction, seeking application of Article 448 of the Civil Code. |
Property and Land Law |
Heirs of Jose Mariano and Helen S. Mariano vs. City of Naga (12th March 2018) |
AK791996 931 Phil. 369 , 858 SCRA 179 , G.R. No. 197743 |
This case concerns an ejectment suit filed by the heirs of landowners against the City of Naga for possessing a 5-hectare property intended for the City Hall. The Supreme Court ruled in favor of the heirs, finding that the purported donation of the land to the City was void due to formal defects in the Deed of Donation and failure to fulfill the condition that the City Hall construction contract be awarded to the landowners' subdivision. The Court held that the City's possession was by mere tolerance, which ceased upon demand by the heirs. | In 1954, City Heights Subdivision offered to donate 5 hectares of land to the City of Naga for the City Hall, conditional on the subdivision being awarded the construction contract. The Municipal Board accepted the donation, and the City took possession and built the City Hall and other government offices. However, the construction contract was awarded to a different contractor. The landowners and their heirs later demanded the return of the property, arguing the condition for donation was not met, and the donation was not properly executed. |
Property and Land Law |
Sangguniang Panlalawigan of Bataan vs. Garcia, Jr. (5th October 2016) |
AK518566 804 SCRA 629 , 796 Phil. 414 , G.R. No. 174964 |
This case involves a petition by the Sangguniang Panlalawigan of Bataan questioning the Court of Appeals' decision that affirmed the Regional Trial Court's order for a writ of mandamus compelling the province to transfer land titles to the Bataan Polytechnic State College (BPSC). The Supreme Court affirmed the lower courts, holding that the subject lands, although titled under the Province of Bataan, are communal lands held in trust for the State and are thus properly transferable to BPSC as mandated by Republic Act No. 8562. | The Province of Bataan owned land occupied by the Medina Lacson de Leon School of Arts and Trades (MLLSAT) and Bataan Community Colleges (BCC). Republic Act No. 8562 converted MLLSAT into Bataan Polytechnic State College (BPSC) and integrated BCC into it, declaring the lands occupied by these schools as property of BPSC and mandating the transfer of titles. The Province of Bataan refused to transfer the titles, claiming the lands were patrimonial property and mortgaged. |
Property and Land Law |
Mercader, Jr. vs. Bardilas (27th June 2016) |
AK382375 788 Phil. 136 , 794 SCRA 387 , G.R. No. 163157 |
This case involves a dispute over a road right of way between adjacent property owners. The petitioners, Spouses Mercader, claimed ownership of a portion of the easement and sought to prevent the respondents, Spouses Bardilas, from asserting their rights as owners of the servient estate. The Supreme Court affirmed the Court of Appeals' decision recognizing the Spouses Bardilas' ownership of the servient estate and right to the road right of way, clarifying that while an easement exists, the servient estate owner retains ownership and can use the property in a manner that doesn't impede the easement's exercise. | The dispute arose between owners of subdivided lots originally part of a larger property. Spouses Mercader and Spouses Bardilas owned adjacent lots, with Spouses Bardilas' lot being burdened by a right of way for the benefit of Spouses Mercader's lot and others to access Clarita Village. A fence erected by the Clarita Village Association restricted the original exit of the right of way, leading to conflicts about encroachment and the extent of rights over the easement. |
Property and Land Law |
Capitol Wireless, Inc. vs. Provincial Treasurer of Batangas (30th May 2016) |
AK786051 791 SCRA 272 , 785 Phil. 712 , G.R. No. 180110 |
This case involves Capitol Wireless, Inc.'s (Capwire) petition against the real property tax assessments on its submarine cable system by the Provincial Treasurer and Assessors of Batangas. The Supreme Court upheld the Court of Appeals' decision, finding that Capwire should have first availed of administrative remedies before resorting to judicial action, as factual questions regarding the cable's location and taxability needed to be resolved. The Court further ruled that submarine cables are taxable real property, akin to electric transmission lines, and are not exempt from real property tax. | Capwire, a telecommunications company, claimed co-ownership of the "Wet Segment" of submarine cable systems laid internationally and reported "Indefeasible Rights in Cable Systems" as property. For loan restructuring, Capwire assessed the value of its right and submitted a sworn statement for real properties. The Provincial Assessor of Batangas then issued real property tax assessments on these cable systems. Capwire contested the assessments, arguing the cables were in international waters and not taxable in the Philippines. |
Property and Land Law |
Alolino vs. Flores (4th April 2016) |
AK909292 788 SCRA 92 , 783 Phil. 605 , G.R. No. 198774 |
This case involves a dispute between neighbors over the construction of a house/sari-sari store by the respondents on a municipal/barrio road adjacent to the petitioner's property. The petitioner claimed that the respondents’ structure obstructed his right to light and view, ingress and egress, and constituted a nuisance. The Supreme Court reversed the Court of Appeals' decision, ruling in favor of the petitioner, ordering the demolition of the respondents' structure and recognizing it as both a public and private nuisance due to its illegal construction on public property. | Petitioner Alolino owned property with a two-story house. Respondents Flores spouses built a house/sari-sari store on an adjacent municipal/barrio road without a building permit. This structure blocked Alolino's light and ventilation and access to the municipal road from his rear door, prompting him to seek its removal. |
Property and Land Law |
Republic vs. Tan (10th February 2016) |
AK918613 783 SCRA 643 , 780 Phil. 764 , G.R. No. 199537 |
This case involves the Republic's petition to reverse the Court of Appeals' decision which affirmed the lower court's grant of Andrea Tan's application for land title registration based on acquisitive prescription. The Supreme Court ruled in favor of the Republic, holding that a declaration of land as alienable and disposable is insufficient to convert it into patrimonial property of the State, which is necessary for acquisitive prescription to run against the State. | Andrea Tan applied for original land registration based on acquisitive prescription, claiming continuous possession of a parcel of land declared alienable and disposable in 1965. The Municipal Trial Court granted her application, which was affirmed by the Court of Appeals. The Republic appealed, arguing that mere declaration of alienability is insufficient for prescription against the State. |
Property and Land Law |
Manila Electric Company vs. The City Assessor (5th August 2015) |
AK880939 765 Phil. 605 , G.R. No. 166102 |
This case involves a petition by Manila Electric Company (MERALCO) contesting the real property tax assessment by the City of Lucena on its electric facilities, including transformers, electric posts, transmission lines, insulators, and electric meters. The Supreme Court ruled that while these facilities are now considered real property and subject to tax under the Local Government Code, the specific 1997 assessment by Lucena City was invalid due to procedural deficiencies in appraisal and notice, violating MERALCO’s right to due process. | MERALCO had been operating in Lucena City since 1922 under various franchises, some of which provided tax exemptions on certain electric facilities. Lucena City began assessing real property tax on MERALCO's electric facilities starting 1985. MERALCO contested these assessments, arguing that its facilities were exempt under its franchise and were personal property, not real property. |
Property and Land Law |
Navy Officers' Village Association, Inc. (NOVAI) vs. Republic (3rd August 2015) |
AK461713 765 Phil. 429 , 764 SCRA 524 , G.R. No. 177168 |
This case concerns the cancellation of a Transfer Certificate of Title (TCT) held by Navy Officers' Village Association, Inc. (NOVAI) over a parcel of land within a former military reservation. The Supreme Court upheld the Court of Appeals' decision that the land remained inalienable public domain and that the deed of sale to NOVAI was void due to the non-existence of the Presidential Proclamation cited as its basis and other irregularities. | The land in question was originally part of Fort William McKinley, later Fort Andres Bonifacio Military Reservation (FBMR). Presidential Proclamation No. 423 reserved a large area for military purposes. Proclamation No. 461 excluded a portion as AFP Officers’ Village, intended for disposal under specific laws. Subsequently, Proclamation No. 478 reserved a smaller portion, including the property in dispute, for veterans rehabilitation. NOVAI claimed to have purchased the land from the Republic based on a Deed of Sale referring to a fictitious Proclamation No. 2487. |
Property and Land Law |
Republic vs. De Guzman Vda. de Joson (10th March 2014) |
AK697117 728 Phil. 550 , 718 SCRA 228 , G.R. No. 163767 |
This case involves the Republic's appeal against the Court of Appeals' decision affirming the lower court's grant of land registration to Rosario de Guzman Vda. de Joson. The Supreme Court reversed the CA and CFI decisions, holding that De Joson failed to sufficiently prove that the land in question was alienable and disposable public land, a necessary requirement for land registration under Section 14(1) of the Property Registration Decree. The Court emphasized that mere possession, even for a long period, is insufficient without proof of the land's alienable and disposable status through a positive act of government. | Rosario de Guzman Vda. de Joson applied for land registration based on her and her predecessors-in-interest's alleged open, continuous, exclusive, and notorious possession and occupation of the land since 1926. The Republic opposed, arguing the land was unclassified forest land and not subject to private appropriation. The CFI and CA ruled in favor of De Joson, but the Republic appealed to the Supreme Court. |
Property and Land Law |
Republic vs. Bacas (20th November 2013) |
AK418209 710 SCRA 411 , 721 Phil. 808 , G.R. No. 182913 |
This case involves a petition by the Republic of the Philippines to annul land titles obtained by private individuals (Bacases and Chabons) for parcels of land within the Camp Evangelista Military Reservation. The Supreme Court ruled in favor of the Republic, declaring the land registration proceedings null and void due to lack of jurisdiction of the Land Registration Court (LRC) over inalienable public land and because the private individuals fraudulently failed to disclose the military reservation and occupancy in their applications. | President Quezon issued Proclamation No. 265 in 1938, reserving land for military purposes, creating Camp Evangelista. Despite this, the Bacases and Chabons filed separate land registration applications in 1964 and 1974, respectively, for parcels within the reservation. The Land Registration Court granted their applications, leading to Original Certificates of Title. The Republic then filed actions to annul these titles. |
Property and Land Law |
Heirs of Mario Malabanan vs. Republic of the Philippines (3rd September 2013) |
AK741804 704 SCRA 561 , 717 Phil. 141 , G.R. No. 179987 |
This case involves a petition for land registration which was denied by the Court of Appeals and initially upheld by the Supreme Court. The Supreme Court resolution addressed motions for reconsideration from both parties, ultimately denying them and reiterating that possession of alienable and disposable public land for registration under Section 14(1) of the Property Registration Decree must be proven to have commenced and been continuous since June 12, 1945, and the land must have been classified as alienable and disposable at the time of application, though not necessarily for the entire duration of possession. | Mario Malabanan applied for land registration in 1998 claiming ownership through purchase and continuous, open, public, and adverse possession for over 30 years, asserting the land was alienable and disposable public land. The Republic opposed, arguing failure to prove the land's alienable and disposable nature and insufficient possession as required by law. |
Property and Land Law |
Pilar Development Corporation vs. Dumadag (11th March 2013) |
AK661257 693 SCRA 96 , 706 Phil. 93 , G.R. No. 194336 |
This case concerns a petition for review on certiorari regarding the dismissal of an accion publiciana filed by Pilar Development Corporation (PDC) against residents who built shanties on its property. The core issue is whether PDC can recover possession of a 3-meter strip of land within its titled property designated as a public easement along Mahabang Ilog Creek. The Supreme Court affirmed the Court of Appeals' decision, holding that the 3-meter strip is a public easement and that the proper party to seek recovery of possession is the Republic of the Philippines or the local government, not PDC. | Pilar Development Corporation claimed ownership of a property within Pilar Village Subdivision, a portion of which was occupied by respondents who built shanties. PDC filed an accion publiciana to evict the respondents, arguing they built without consent on land designated for village recreational facilities. The respondents countered that the local government, not PDC, had jurisdiction over the area. The trial court and the Court of Appeals dismissed PDC's complaint, finding the occupied area was a public easement. |
Property and Land Law |
Matthews vs. Taylor (22nd June 2009) |
AK576607 590 SCRA 394 , 608 Phil. 193 , G.R. No. 164584 |
This case involves a petition to nullify a lease agreement entered into by a Filipina wife, Joselyn Taylor, without her British husband, Benjamin Taylor's consent. The Supreme Court ultimately ruled in favor of the petitioner, Philip Matthews, upholding the validity of the lease agreement. The Court held that Benjamin, as an alien, had no standing to question the lease because the Boracay property was exclusively owned by his Filipino wife, and the Constitution prohibits aliens from owning land in the Philippines. | Benjamin Taylor, a British citizen, and Joselyn Taylor, a Filipina, were married. Joselyn purchased a property in Boracay using funds allegedly provided by Benjamin and developed it into a resort. Later, without Benjamin's express consent, Joselyn leased the property to Philip Matthews. Benjamin filed a case to nullify the lease agreement arguing it was void without his consent as the property was community property and his funds were used for its acquisition. |
Property and Land Law |
Rufloe vs. Burgos (30th January 2009) |
AK442785 577 SCRA 264 , 597 Phil. 261 , G.R. No. 143573 |
This case involves a dispute over land ownership originating from a forged Deed of Sale. The Supreme Court determined whether subsequent buyers of the property, after the forged sale, could be considered innocent purchasers for value and thus acquire valid title, ultimately ruling against them due to the presence of a notice of adverse claim and other circumstances indicating bad faith. | The case stems from a property originally owned by the Rufloe spouses. A Deed of Sale was forged, purportedly signed by the Rufloes, transferring the property to Elvira Delos Reyes. Delos Reyes then sold the property to the Burgos siblings, who later sold it to their aunt, Leonarda Burgos. The Rufloes filed a case to nullify these transactions, claiming forgery and asserting their continued ownership. |
Property and Land Law |
Heirs of Marcelino Doronio vs. Heirs of Fortunato Doronio (27th December 2007) |
AK570269 541 SCRA 479 , 565 Phil. 766 , G.R. No. 169454 |
This case involves a dispute over land ownership between the heirs of two brothers, Marcelino and Fortunato Doronio. The petitioners, heirs of Marcelino, claimed full ownership based on a private deed of donation propter nuptias executed in favor of their predecessors and a subsequent registration of title. The respondents, heirs of Fortunato, argued that the donation only covered half of the property and that the deed was invalid for not being a public instrument. The Supreme Court ruled in favor of the respondents, declaring the donation propter nuptias void for lack of a public instrument and ordering the restoration of the original certificate of title. | Spouses Simeon Doronio and Cornelia Gante owned a parcel of land covered by Original Certificate of Title No. 352. They had children, including Marcelino and Fortunato Doronio. Simeon and Cornelia executed a private deed of donation propter nuptias in favor of Marcelino and his wife Veronica Pico. The description in the deed of donation differed slightly from OCT No. 352 regarding adjacent property owners. Petitioners, heirs of Marcelino, registered the deed through a petition case without naming respondents, heirs of Fortunato, leading to a new TCT in their predecessor's name, covering the entire property. Respondents contested this, claiming only half was intended for donation and the donation was invalid. |
Property and Land Law |
Manotok Realty, Inc. vs. CLT Realty Development Corporation (14th December 2007) |
AK258876 540 SCRA 304 , 565 Phil. 59 , G.R. No. 123346 , G.R. No. 134385 |
This case involves two consolidated petitions concerning land ownership claims over portions of the Maysilo Estate, all tracing back to Original Certificate of Title (OCT) No. 994. The central controversy revolves around conflicting interpretations of OCT No. 994, particularly its date of registration, with contentions arising from an apparent discrepancy between April 19, 1917 (decree issuance) and May 3, 1917 (transcription date). The Supreme Court, sitting en banc, ultimately remands the cases to the Court of Appeals for a Special Division to factually determine the validity of the contending titles, emphasizing that only titles derived from the genuine OCT No. 994 registered on May 3, 1917 can be considered valid and that titles originating from a non-existent OCT No. 994 dated April 19, 1917 are void. | The dispute centers on ownership claims over portions of the vast Maysilo Estate, all purportedly originating from OCT No. 994. Conflicting claims arose between Manotok Realty and Manotok Estate Corporation versus CLT Realty Development Corporation in one case, and Araneta Institute of Agriculture, Inc. versus the Heirs of Jose B. Dimson in the other. These cases reached the Supreme Court after conflicting decisions in the lower courts and the Court of Appeals concerning the validity of the parties' titles. Prior Supreme Court decisions in MWSS v. Court of Appeals and Gonzaga v. Court of Appeals had previously addressed claims emanating from OCT No. 994, but inconsistencies and new factual evidence necessitated a re-examination. |
Property and Land Law |
Heirs of Marcelina Arzadon-Crisologo vs. Rañon (5th September 2007) |
AK869857 532 SCRA 391 , 559 Phil. 169 , G.R. No. 171068 |
This case revolves around a dispute over ownership of an unregistered residential lot in Ilocos Norte. The Heirs of Arzadon-Crisologo claimed ownership through succession and prescription, while Agrifina Rañon, later substituted by her heirs, asserted ownership through extraordinary acquisitive prescription based on long-term possession and tax payments. The Supreme Court affirmed the Court of Appeals' decision, ruling in favor of the Rañons, holding that they had acquired ownership through extraordinary acquisitive prescription due to their continuous, public, and adverse possession for over thirty years, unchallenged by the petitioners. | Agrifina Rañon filed a complaint against spouses Montemayor to quiet title over a residential lot, claiming ownership based on long and continuous possession since 1962. The Heirs of Arzadon-Crisologo intervened, asserting their rights as successors-in-interest of the original owners and claiming that Rañon's possession was not in good faith and did not ripen into ownership. The spouses Montemayor were later dropped as parties as they had repurchased the property from the Arzadons. The Municipal Circuit Trial Court (MCTC) initially ruled in favor of the Arzadon heirs, but the Regional Trial Court (RTC) reversed this decision, favoring the Rañons through acquisitive prescription. The Court of Appeals affirmed the RTC’s decision. |
Property and Land Law |
Preysler, Jr. vs. Court of Appeals (11th July 2006) |
AK116882 494 SCRA 547 , 527 Phil. 129 , G.R. No. 158141 |
This case concerns a dispute over right of way between a property owner (Petitioner) whose land is surrounded by a subdivision and the subdivision owner (Respondent). The Supreme Court reviewed a Court of Appeals decision regarding a preliminary injunction related to access through the subdivision roads. The Court clarified the nature of preliminary injunction as maintaining status quo, distinguished between temporary and permanent easements, and ultimately remanded the case to the trial court to determine the indemnity for a temporary easement. | Petitioner owned landlocked parcels adjacent to Respondent's Tali Beach Subdivision, needing access through the subdivision roads. Respondent initially allowed access but later barricaded the property. Petitioner sought a right of way and preliminary injunction. The trial court initially granted a preliminary injunction to remove barricades and allow passage. This was later amended to include passage for contractors, equipment, and power line installation. |
Property and Land Law |
Portic vs. Cristobal (22nd April 2005) |
AK058410 456 SCRA 577 , 496 Phil. 456 , G.R. No. 156171 |
This case involves a dispute over ownership of property stemming from a contract to sell. The Supreme Court determined that the agreement between the parties was a contract to sell, not a contract of sale, because ownership was explicitly reserved by the vendors (Spouses Portic) until full payment of the purchase price by the vendee (Cristobal). Since full payment was not made, the Court ruled that ownership remained with the vendors and upheld their action to quiet title, reversing the Court of Appeals decision which favored the vendee. | Spouses Portic sold property to Anastacia Cristobal under an agreement that included conditions about payment of a balance. A dispute arose when Cristobal registered the title in her name despite allegedly not fully paying the balance, and Spouses Portic sought to quiet title, claiming the sale was void due to non-payment. |
Property and Land Law |
National Housing Authority vs. Court of Appeals (13th April 2005) |
AK266478 456 SCRA 17 , 495 Phil. 693 , G.R. NO. 148830 |
This case involves a dispute over the location and extent of a seven-hectare usufruct granted to Manila Seedling Bank Foundation, Inc. (MSBF) within a larger property owned by the National Housing Authority (NHA). Bulacan Garden Corporation (BGC), leasing a portion from MSBF, sought to enjoin NHA's demolition of its facilities. The Supreme Court remanded the case for a joint survey to definitively determine the boundaries of MSBF's usufructuary area, emphasizing MSBF's right to choose the location within the larger property but also its responsibility to respect the seven-hectare limit. | President Marcos issued Proclamation No. 481 reserving a 120-hectare NHA-owned land for the National Government Center (NGC). Later, Proclamation No. 1670 segregated seven hectares from the NGC and granted MSBF usufructuary rights over it, to be determined by future survey. MSBF occupied an area exceeding seven hectares and leased a portion to BGC. NHA, under Memorandum Order No. 127 which revoked the reserved status of the remaining 50 hectares, sought to demolish BGC's facilities, leading BGC to file for injunction. |
Property and Land Law |
Baloloy vs. Hular (9th September 2004) |
AK688555 438 SCRA 80 , 481 Phil. 398 , G.R. No. 157767 |
This case involves a petition for review on certiorari regarding a land dispute. Alfredo Hular filed a complaint to quiet title and for reconveyance of land, claiming ownership through his father's acquisition and acquisitive prescription. The Supreme Court reversed the Court of Appeals and Regional Trial Court decisions, finding that Hular failed to implead indispensable parties (his siblings and the Republic of the Philippines) and failed to sufficiently prove his claim of ownership against the Torrens title of the Baloloys. | Alfredo Hular claimed ownership of land originally owned by his father, Astrologo Hular, part of Lot No. 3347. He alleged that Iluminado Baloloy fraudulently secured a Free Patent and OCT over Lot No. 3353, which included a portion of his father's land (later found to be 1,405 square meters, not 287 sqm as initially thought). Hular sought to quiet title, nullify the Baloloy's OCT, and reconveyance, citing prior ownership and acquisitive prescription. Baloloys, heirs of Iluminado, argued their title's sanctity and Hular's lack of cause of action. |
Property and Land Law |
Heirs of Emiliano Navarro vs. Intermediate Appellate Court (13th October 1997) |
AK197612 345 Phil. 810 , G.R. No. 68166 |
This is a Resolution by the Supreme Court addressing an Omnibus Motion filed by the Heirs of Pascual seeking clarification, reconsideration, and remand of the Court's prior decision. The Court found no merit in the motion for reconsideration and remand but acknowledged and rectified typographical and clerical errors in its previous decision to harmonize the body and dispositive portion of the ruling. | The case involves a land dispute where the Heirs of Navarro originally filed a Petition for Review. The Supreme Court issued a Decision on February 12, 1997, which the Heirs of Pascual found confusing, particularly the dispositive portion in relation to the body of the decision regarding the public domain nature of the land. This confusion led to the Omnibus Motion seeking clarification, reconsideration, and remand. |
Property and Land Law |
Sia vs. Court of Appeals (5th May 1997) |
AK070235 272 SCRA 141 , 338 Phil. 652 , G.R. No. 108222 |
This case revolves around an ejectment suit filed by Torre de Oro Development Corporation against Henry L. Sia, a lessee of their property. The core issue is whether Sia, as a lessee who constructed a building on the leased land, has the right to retain possession until reimbursed for the building's value, based on Articles 448 and 546 of the Civil Code, or if his rights are limited to Article 1678 of the Civil Code governing lessees' improvements. The Supreme Court affirmed the Court of Appeals' decision, holding that Article 1678, not Articles 448 and 546, applies to lessees, thus denying Sia's right to retain possession and ordering his ejectment based on the expired lease contract. | Atty. Rodolfo N. Pelaez originally owned the land and leased it to Henry L. Sia's parents who built a structure on it with permission in 1970. After Rodolfo Pelaez passed away, the land was inherited by his son, Atty. Pacifico Pelaez, who then sold it to Torre de Oro Development Corporation. Henry L. Sia succeeded his parents as lessee. Torre de Oro Development Corporation and Sia entered into a new one-year lease contract in 1988. Upon expiry, the lessor decided not to renew the lease and sought to eject Sia, leading to this legal dispute concerning Sia's rights as a lessee with improvements on the land. |
Property and Land Law |
Eduarte vs. Court of Appeals (9th February 1996) |
AK813360 253 SCRA 391 , 323 Phil. 462 , G.R. No. 105944 |
This case involves a petition for certiorari assailing the Court of Appeals' decision which affirmed the trial court's revocation of a donation due to ingratitude and declared petitioners as purchasers in bad faith. The Supreme Court reviewed whether falsification of a deed of donation constitutes ingratitude justifying revocation, the validity of forgery findings, and whether the petitioners were indeed purchasers in bad faith. Ultimately, the Supreme Court partly granted the petition, reversing the finding of bad faith and shifting liability for damages to the fraudulent donee, while upholding the revocation of the donation. | Pedro Calapine donated land to his niece, Helen Doria. Later, he claimed that a second deed of donation conveying the entire property was forged by Doria and sought to revoke the donation due to her ingratitude. Doria then sold the land to Spouses Eduarte. The lower courts sided with Calapine, revoking the donation and declaring the Eduartes buyers in bad faith, leading to this appeal. |
Property and Land Law |
Solid Manila Corporation vs. Bio Hong Trading Co (8th April 1991) |
AK658021 195 SCRA 748 , 273 Phil. 115 , G.R. No. 90596 |
This case concerns a dispute over a right-of-way easement. The Supreme Court ruled that a personal easement for the benefit of the public existed on a private alley, and that this easement was not extinguished by the subsequent purchase of the property by Bio Hong Trading Co., Inc., rejecting the argument of merger. The Court upheld the trial court’s decision for injunction, ordering the removal of obstructions placed by Bio Hong and emphasizing the concept of "law of the case" due to a prior related decision. | Solid Manila Corporation claimed a right-of-way over a private alley located on property owned by Bio Hong Trading Co., Inc. This alley was established by a prior owner and annotated on Bio Hong's title. Bio Hong constructed steel gates obstructing the alley, leading Solid Manila to file for injunction to remove the gates and enforce the easement. |
Property and Land Law |
Ronquillo vs. Court of Appeals (20th March 1991) |
AK198213 195 SCRA 433 , 272-A Phil. 412 , G.R. No. 43346 |
This case involves a dispute over the ownership of a dried-up portion of Estero Calubcub. The Supreme Court reversed the Court of Appeals' decision, holding that the estero's drying up was due to human intervention (garbage dumping), not natural causes, thus Article 370 of the old Civil Code regarding riparian ownership of naturally abandoned riverbeds does not apply. The dried-up estero remains public land. | Rosendo del Rosario and his daughters claimed ownership of a dried-up estero portion adjacent to their titled land, asserting riparian rights. Mario Ronquillo occupied this portion and claimed it was public land. The Director of Lands and Development Bank of the Philippines were later impleaded as respondents. |
Property and Land Law |
Jagualing vs. Court of Appeals (4th March 1991) |
AK813608 194 SCRA 607 , 272 Phil. 439 , G.R. No. 94283 |
This case concerns a dispute over the ownership of an island formed in the Tagoloan River, a non-navigable and non-floatable river. The Supreme Court resolved the issue of whether the possessors of the island or the owners of the adjacent land margin have a better right to the island, ultimately affirming the Court of Appeals' decision that favored the riparian owners based on the principles of accretion and riparian rights under the Civil Code. | The Eduaves, private respondents, filed an action to quiet title over a parcel of land that had become an island in the Tagoloan River against the Jagualings, petitioners, who were in possession of the island. The Eduaves claimed ownership through inheritance and presented evidence of tax declarations and acts of ownership on the land prior to its becoming an island. The Jagualings claimed ownership through adverse possession. |
Property and Land Law |
Republic vs. Intermediate Appellate Court (4th June 1990) |
AK579538 186 SCRA 88 , 264 Phil. 450 , G.R. No. 73085 |
This case involves a land dispute where private respondents claimed ownership of land within a declared forest reserve and national park based on a Spanish title. The Supreme Court ruled against the private respondents, reiterating that forest lands and national parks are inalienable public land and cannot be subject to private appropriation or registration, regardless of alleged Spanish titles, especially after the enactment of Presidential Decree No. 892. | Private respondents filed a complaint for quieting of title, asserting ownership over land based on a Spanish title. The Republic of the Philippines argued that the land was part of a forest reserve and national park, making it inalienable public land not subject to private ownership. The trial court and the Intermediate Appellate Court initially ruled in favor of the private respondents. |
Property and Land Law |
Spouses Del Campo vs. Abesia (15th April 1988) |
AK305738 160 SCRA 379 , 243 Phil. 532 , No. L-49219 |
This case examines whether Article 448 of the Civil Code, concerning builders in good faith, applies when co-owners partition their property and one co-owner's house encroaches on the portion allocated to another. The Supreme Court ruled that Article 448 can be applicable post-partition if the encroachment was built in good faith, modifying the lower court's decision which initially deemed it inapplicable within co-ownership. | Spouses Del Campo and Bernarda Abesia were co-owners of a small parcel of land. During a partition action, it was discovered that Abesia's house slightly encroached onto the portion allocated to the Del Campos. The core issue was whether Abesia, as a co-owner builder, could invoke the rights of a builder in good faith under Article 448. |
Property and Land Law |
Escritor, Jr. vs. Intermediate Appellate Court (12th November 1987) |
AK429625 239 Phil. 563 , 155 SCRA 577 , No. L-71283 |
This case involves a dispute over land ownership and the liability of possessors for damages. The petitioners, heirs of Miguel Escritor, were ordered by the Intermediate Appellate Court to pay damages to respondent Simeon Acuna for unlawful possession, based on a later court decision reversing the initial adjudication of the land to Escritor. The Supreme Court reversed the appellate court, holding that the petitioners were possessors in good faith and thus not liable for damages, as Escritor had originally been awarded the land by a court of competent jurisdiction, and good faith is presumed. | The case originates from a cadastral proceeding where Miguel Escritor claimed ownership of a land lot based on inheritance. The Court of First Instance initially adjudicated the land to Escritor. Years later, Simeon Acuna filed a petition for review alleging fraud and misrepresentation in Escritor's acquisition. This petition was eventually granted, and the land was adjudicated to Acuna. Acuna then sued Escritor's heirs for damages for unlawful possession of the land during the period between the initial adjudication and its reversal. |
Property and Land Law |
Director of Lands vs. Intermediate Appellate Court (29th December 1986) |
AK048318 146 SCRA 509 , 230 Phil. 590 , No. L-73002 |
This case involves a land registration dispute where the Director of Lands appealed a decision confirming Acme Plywood's title to land acquired from members of a cultural minority. The central issue is whether Acme Plywood, a corporation, could validly register land acquired in 1962 when the registration proceedings began in 1981, considering the 1973 Constitution's restrictions on corporate land ownership from the public domain. The Supreme Court upheld the registration in favor of Acme Plywood, reversing its previous stance in Meralco case and reaffirming the doctrine of vested rights and ipso jure conversion of public land to private land through long-term possession. | Acme Plywood & Veneer Co., Inc. sought to register five parcels of land acquired from Mariano and Acer Infiel, members of the Dumagat tribe, through land registration proceedings under Section 48 of the Public Land Act. The Director of Lands opposed the registration, arguing that because the proceedings started after the 1973 Constitution came into effect, the corporation was disqualified from owning public land according to the new constitution. |
Property and Land Law |
Heirs of Jose Amunategui vs. Director of Forestry (29th November 1983) |
AK724137 126 SCRA 69 , 211 Phil. 260 , No. L-27873 , No. L-30035 |
This case involves two consolidated petitions questioning the Court of Appeals' decision that declared a disputed parcel of land as forest land, not subject to private titling. The Supreme Court affirmed, holding that forest lands remain part of the public domain and cannot be registered in favor of private individuals based on possession, no matter how long, unless officially declassified by the government. | The case originated from an application for land registration filed in the Court of First Instance of Capiz for Lot No. 885. Several oppositions were filed, including one from the Director of Forestry, who argued the land was forest land. The Court of First Instance partially granted the application to private litigants, but this was appealed. |
Property and Land Law |
People vs. Narvaez (20th April 1983) |
AK862181 121 SCRA 389 , 206 Phil. 314 , Nos. L-33466-67 |
Mamerto Narvaez was convicted of murder for killing two men who were fencing a disputed property, obstructing access to his house and ricemill. The Supreme Court modified the conviction to homicide, appreciating incomplete self-defense and mitigating circumstances of voluntary surrender and passion/obfuscation, reducing his sentence significantly due to disproportionate defense and considering the context of a long-standing land dispute. | Narvaez, a settler in South Cotabato, was embroiled in a land dispute with Fleischer and Company. He had been leasing a portion of the land in contention, but the company sought to remove him and other settlers. The deceased victims, Davis Fleischer and Flaviano Rubia, were secretary-treasurer and assistant manager of Fleischer & Co. respectively, and were fencing the land when Narvaez shot them. |
Property and Land Law |
Azarcon vs. Vallarta (28th October 1980) |
AK487327 100 SCRA 450 , 188 Phil. 481 , No. L-43679 |
This case concerns a land ownership dispute over a parcel of riceland between the Azarcons, holding a Free Patent Title, and the Vallartas, holding an Original Certificate of Title from registration proceedings. The Supreme Court upheld the Vallartas' title, finding the Azarcons' title null and void due to misrepresentation in their free patent application, as the land was private property, not public domain, at the time of issuance. | The contested land was originally owned by Dr. Jose V. Cajucom, who sold it in two separate transactions. First, to the Vallartas' predecessors in 1932, and later to the Azarcons in 1959. Both parties subsequently obtained titles, leading to conflicting claims of ownership over the same property. |
Property and Land Law |
Purugganan vs. Paredes (21st January 1976) |
AK605464 69 SCRA 69 , 161 Phil. 91 , No. L-23818 |
This case concerns a dispute over an easement of drainage between neighboring landowners. The Supreme Court upheld the summary judgment of the lower court, finding that the defendants-appellants violated the terms of the easement and failed to establish a genuine issue of material fact. | Plaintiff Purugganan owned lots burdened by a registered easement of drainage in favor of Defendant Paredes' adjacent property. Paredes constructed a house that exceeded the easement's specifications, causing rainwater to improperly drain onto Purugganan's property. Purugganan sued to enforce the easement, while Paredes claimed her house was pre-existing and not in violation. |
Property and Land Law |
Tumalad vs. Vicencio (30th September 1971) |
AK332768 41 SSCRA 143 , 148-B Phil. 625 , No. L-30173 |
This case, certified from the Court of Appeals, resolves whether a house built on rented land can be validly subjected to a chattel mortgage. The Supreme Court ruled that parties can agree to treat a house on rented land as personal property for chattel mortgage purposes, especially when explicitly stated in the contract. The court also addressed the issue of rent payment during the redemption period after extrajudicial foreclosure, ruling that the mortgagor is not obligated to pay rent to the purchaser during this period unless the purchaser has taken legal steps to gain possession. | Defendants-Appellants executed a chattel mortgage over their house, built on rented land, to Plaintiffs-Appellees to secure a loan. Upon default, Plaintiffs-Appellees extrajudicially foreclosed the mortgage and purchased the house at auction. Plaintiffs-Appellees then filed an ejectment case against Defendants-Appellants in the municipal court to recover possession and collect rent. |
Property and Land Law |
Province of Zamboanga del Norte vs. City of Zamboanga (28th March 1968) |
AK384710 22 SCRA 1334 , 131 Phil. 446 , No. L-24440 |
This case involves a dispute over the ownership of 50 real properties initially owned by the defunct Zamboanga Province and located within Zamboanga City. Republic Act 3039 transferred these properties to Zamboanga City for free, amending Commonwealth Act 39 which had originally required the city to purchase them. The Supreme Court had to determine whether these properties were public or patrimonial to decide if the free transfer was constitutional, ultimately ruling that some were public and validly transferred, while others were patrimonial and could not be transferred without just compensation to Zamboanga del Norte, the successor-in-interest of the defunct province. | The Municipality of Zamboanga was the capital of Zamboanga Province. Commonwealth Act 39 converted the Municipality into Zamboanga City and stipulated that the City would purchase provincial properties in Zamboanga City when the capital moved. The capital moved to Dipolog, and later Republic Act 711 divided Zamboanga Province into Zamboanga del Norte and Zamboanga del Sur. Republic Act 3039 later amended Commonwealth Act 39 to transfer the properties to Zamboanga City for free, leading to this legal challenge by Zamboanga del Norte, seeking payment for its share of the properties. |
Property and Land Law |
Caltex (Phil.) Inc. vs. Felias (30th June 1960) |
AK597591 108 Phil. 873 , No. L-14309 |
This case involves a dispute over the ownership of a land parcel levied and sold to Caltex to satisfy the debt of Felisa Felias's husband. The Supreme Court affirmed the Court of Appeals' decision, holding that the land was Felisa Felias's paraphernal property, not conjugal, and therefore not liable for her husband's debt, as it was donated to her before the conjugal dwelling was built. | Caltex sought to enforce a judgment against Felisa Felias's husband, Simeon Sawamoto, by levying and selling a land parcel (Lot No. 107) originally owned by Felisa Felias's parents and later donated to her. Caltex claimed the land became conjugal property due to the construction of a conjugal house on it during the marriage and was thus subject to levy for the husband’s debt. |
Property and Land Law |
Evangelista vs. Alto Surety & Ins. Co., Inc. (23rd April 1958) |
AK523989 103 Phil. 401 , No. L-11139 |
This case concerns a dispute over ownership of a house built by a lessee on leased land. The Supreme Court determined whether the house should be considered movable or immovable property for purposes of attachment and execution. The Court ruled that a house is immovable property regardless of who built it or the agreements between private parties, and thus, Evangelista's prior attachment, properly executed for immovable property, prevailed over Alto Surety's later sale. | Santos Evangelista sued Ricardo Rivera for a sum of money and obtained a writ of attachment on a house Rivera built on leased land. Later, Alto Surety & Insurance Co., Inc. claimed ownership of the same house based on a prior auction sale resulting from a separate case against Rivera. Evangelista sued to establish his title and gain possession. |
Property and Land Law |
Espique vs. Espique (28th June 1956) |
AK645404 99 Phil. 448 , No. L-8029 |
Plaintiffs sued for partition of land, claiming common ownership. Defendant countered that the land was donated to him propter nuptias in 1906 and he possessed it adversely for 44 years. The Supreme Court affirmed the dismissal of the partition suit, ruling that although the donation was invalid for lack of a public document, it served as a valid basis for acquisitive prescription given the defendant's long, adverse, and continuous possession. | The case stemmed from a partition action where plaintiffs claimed common ownership of land and sought damages for lost profits. The defendant asserted sole ownership based on a donation propter nuptias received in 1906 and his subsequent adverse possession for over 40 years, arguing for prescription and lack of cause of action for partition. |
Property and Land Law |
Cruz vs. Pahati (13th April 1956) |
AK018322 98 Phil. 788 , No. L-8257 |
This case involves a dispute over the ownership of an automobile fraudulently sold by a third party, Belizo. The Supreme Court ruled in favor of the original owner, Cruz, holding that even a buyer in good faith, Bulahan, could not acquire valid title from a seller who did not have rightful ownership, as the original owner was unlawfully deprived of the vehicle through fraud. | Plaintiff Cruz owned an automobile. He entrusted it to Belizo, along with a letter intended to request a new registration certificate, under the pretext that Belizo would find a buyer. Belizo, however, fraudulently altered the letter into a deed of sale and sold the car to Bulahan, who then sold it to Pahati. Cruz filed a replevin action to recover the automobile. |
Property and Land Law |
Davao Saw Mill Co. vs. Castillo (7th August 1935) |
AK655680 61 Phil. 709 , No. 40411 |
This case addresses whether sawmill machinery installed by a lessee on leased land becomes real property by virtue of being attached to the land for industry, or if it remains personal property, especially in light of a lease agreement excluding machinery from improvements that would accrue to the lessor. The Supreme Court affirmed the trial court's decision that the machinery remained personal property, thus upholding its levy and sale as personalty. | Davao Saw Mill operated a sawmill business on land it leased. They erected a building and installed machinery within it, some affixed to cement foundations. A lease agreement stipulated that improvements and buildings would become the property of the landowner upon lease expiration, but specifically excluded machineries from these improvements. |
Property and Land Law |
Sibal vs. Valdez (4th August 1927) |
AK944731 50 Phil. 512 , No. 26278 |
This case addresses whether standing sugar cane should be considered personal or real property for purposes of attachment and redemption. The Supreme Court ruled that under prevailing jurisprudence and statutory modifications to the Civil Code, annually cultivated crops like sugar cane are considered personal property and thus not subject to redemption as real property. The Court modified the lower court's judgment regarding damages, adjusting the amounts for sugar cane, sugar cane shoots, and harvested palay. | This case arose from a dispute over sugar cane and palay (rice) crops planted on land previously owned by the plaintiff, Leon Sibal, but later involved in execution sales. Sibal attempted to redeem sugar cane sold to the defendant, Emiliano Valdez, and sought to prevent Valdez from harvesting palay on the same land. The core issue revolves around the classification of standing crops as either personal or real property under Philippine law. |
Property and Land Law |
Pensader vs. Pensader (7th February 1924) |
AK902639 47 Phil. 959 , No. 21271 |
This case involves a dispute over the partition of coconut land claimed by plaintiffs as heirs of Canuto Pensader, asserting it as undivided inheritance, against defendants, Alejandra Pensader and her son Silverio Revelar, who claimed exclusive ownership via donation and adverse possession. The Supreme Court affirmed the lower court's decision, finding the defendants' long-term, adverse possession had prescribed the plaintiffs' action for partition. | The case centers on a claim of inheritance versus a claim of ownership through donation and adverse possession. The plaintiffs, nephews of the deceased Canuto Pensader, sought to partition land they considered common inheritance. The defendants, niece and grand-nephew of Canuto, asserted exclusive rights based on donations made by Canuto and decades of uninterrupted possession. The legal context is property rights, inheritance laws, donation, and the principle of prescription through adverse possession. |
Property and Land Law |
Osorio vs. Osorio and Ynchausti Steamship Co. (30th March 1921) |
AK543470 41 Phil. 531 , No. 16544 |
This case concerns the validity of a donation made by a widow, Da. Petrona Reyes, to her son, Leonardo Osorio, of her share in her deceased husband's shipping business inheritance, specifically shares of stock in Ynchausti Steamship Co. The central issue is whether the donation made before the formal adjudication of the inheritance is valid under Article 635 of the Civil Code, which prohibits donation of future property. The Supreme Court upheld the donation, finding that the widow had a vested right to her inheritance at the time of donation. | D. Antonio Osorio had a share in a shipping business with Ynchausti & Co. Upon his death, his estate, including this share, was to be partitioned among his heirs, including his widow Da. Petrona Reyes. Before the formal partition, Da. Petrona Reyes donated a portion of her expected inheritance to her son, Leonardo Osorio. This donation later became contested when the shares of stock representing the inherited business interest were inventoried as part of Da. Petrona Reyes' estate after her death. |
Property and Land Law |
Mendoza vs. De Leon (15th February 1916) |
AK987030 33 Phil. 508 , No. 9596 |
This case involves an action for damages filed by Marcos Mendoza against the municipal council members of Villasis, Pangasinan, for unlawfully revoking his exclusive ferry privilege lease, awarded under Act No. 1634, and granting it to another person. The Supreme Court determined whether the council members were personally liable for damages arising from the rescission of the lease contract. | Marcos Mendoza was granted an exclusive ferry privilege by the municipality of Villasis under Act No. 1634. After operating the ferry for over a year, the municipal council, composed of the defendants, revoked his lease and awarded a franchise to another person, leading to Mendoza's forcible ejection. Mendoza then sued the individual council members for damages. |
Property and Land Law |
Legarda and Prieto vs. Saleeby (2nd October 1915) |
AK159516 31 Phil. 590 , No. 8936 |
This case resolves a dispute arising from double registration under the Torrens system, where both the plaintiff and defendant obtained certificates of title for overlapping land portions including a wall. The Supreme Court ruled that in cases of double registration, the holder of the earlier certificate of title prevails, emphasizing the principle of indefeasibility and notice inherent in the Torrens system to ensure land title security. | Two owners of adjacent lots in Manila, Legarda and Saleeby, both registered their lands under the Torrens system. A stone wall situated on Legarda's property was mistakenly included in both their initial registration and Saleeby's subsequent registration, leading to conflicting claims over the wall and the land it occupied. |
Property and Land Law |
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