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Pante vs. People

18th January 2021

ak603265
969 SCRA 243 , 894 Phil. 54 , G.R. No. 218969
Primary Holding
A person who receives lost property from the original finder and subsequently misappropriates it, knowing it is not rightfully theirs, is considered a "finder in law" and can be held liable for theft under Article 308, par. 2(1) of the Revised Penal Code for failing to return the property to the owner or authorities.
Background
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
Primary Holding
The Petition for Review is granted; the Court of Appeals' Decision and Resolution are set aside; the action for forcible entry is deemed to have prescribed, and the Municipal Trial Court in Cities had no jurisdiction over the case.
Background
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
Primary Holding
Article 448 of the Civil Code regarding builders in good faith is not applicable in condominium settings governed by the Condominium Act, Master Deed, and By-Laws. Condominium corporations, acting through their Board of Directors, have the right to abate constructions violating the Master Deed and By-Laws, and unit owners cannot unilaterally expand their units onto common areas.
Background
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
Primary Holding
The Supreme Court reversed the Court of Appeals' Amended Decision and reinstated the Regional Trial Court's decision, as modified. It ordered the City of Naga to vacate the subject property, peacefully surrender possession to the petitioners, pay a monthly rental of PHP 2,500,000 (later modified to PHP 75,000 for attorney's fees), and recognized that the donation was void and the petitioners had a better right to possession based on their Torrens title.
Background
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
Primary Holding
The Supreme Court held that the subject parcels of land are considered communal property of the State, held in trust by the Province of Bataan, and therefore are subject to the absolute control and disposition of the National Government through Congress. A writ of mandamus compelling the transfer of land titles to BPSC was correctly issued.
Background
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
Primary Holding
The owner of the servient estate retains ownership of the portion of land burdened by a road right of way easement and may use it, provided such use does not hinder the easement's purpose. The phrase "with existing Right of Way" in a title doesn't automatically grant the dominant estate ownership of the easement area.
Background
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
Primary Holding
The Supreme Court denied Capwire's petition, affirming the dismissal of its appeal. The Court held that Capwire should have exhausted administrative remedies before resorting to court action because factual issues were involved, and that submarine communication cables are considered taxable real property.
Background
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
Primary Holding
The respondents' house/sari-sari store, illegally constructed on a barrio road (public property), is deemed a public and private nuisance per se and must be demolished. The reclassification of the barrio road to residential by the Sanggunian resolution was ineffective because it was not done through a valid ordinance approved by two-thirds of the Sanggunian members.
Background
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
Primary Holding
A declaration that government-owned land is alienable and disposable does not, by itself, convert it into patrimonial property of the State; an express declaration that the land is no longer intended for public use or public service is required for acquisitive prescription to apply against the State.
Background
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
Primary Holding
The Supreme Court affirmed the Court of Appeals' decision in part, declaring that MERALCO's electric facilities are subject to real property tax under the Local Government Code. However, it nullified the 1997 appraisal and assessment by the City Assessor of Lucena due to violation of MERALCO's right to due process and ordered a new assessment to be conducted in accordance with the Local Government Code.
Background
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
Primary Holding
Land reserved for public or quasi-public purposes remains inalienable public domain unless explicitly withdrawn from such reservation by law or presidential proclamation and positively declared alienable and disposable. A sale of inalienable public land is void ab initio, and the title issued based on such sale is also void.
Background
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
Primary Holding
The application for land registration is denied because the applicant failed to discharge the burden of proving that the subject land is alienable and disposable land of the public domain, a prerequisite for registration under Section 14(1) of the Property Registration Decree.
Background
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
Primary Holding
The Supreme Court reversed the Court of Appeals and Regional Trial Court decisions, holding that the Land Registration Court lacked jurisdiction to register inalienable public land, specifically land within a military reservation, and that the land titles obtained through fraudulent applications are void ab initio and must be cancelled.
Background
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
Primary Holding
The motions for reconsideration from both the petitioners and the respondent are denied, reaffirming the original decision that the petitioners failed to sufficiently prove their right to land registration because they did not establish possession and occupation of the property or by their predecessors-in-interest since June 12, 1945, nor did they fully comply with the requirements of Section 14(1) or 14(2) of the Property Registration Decree and Section 48(b) of the Public Land Act.
Background
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
Primary Holding
Pilar Development Corporation cannot recover possession of the 3-meter strip of land designated for public easement because it is considered part of the public dominion. The proper party to institute an action concerning this public easement is the Republic of the Philippines through the Office of the Solicitor General or the local government of Las Piñas City.
Background
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
Primary Holding
The Agreement of Lease between Joselyn Taylor and Philip Matthews is valid because Benjamin Taylor, the alien husband, has no legal right to nullify the lease on property exclusively owned by his Filipino wife. Aliens are constitutionally prohibited from owning land in the Philippines, thus Benjamin's claim of ownership or need for consent is without legal basis.
Background
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
Primary Holding
The respondents, including the Burgos siblings and Leonarda Burgos, were not innocent purchasers for value. Consequently, they did not acquire a valid title to the property despite relying on Transfer Certificates of Title derived from a forged Deed of Sale. The original title of the Rufloe spouses was reinstated.
Background
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
Primary Holding
The private deed of donation propter nuptias of real property executed in 1919 under the Old Civil Code is void for not being in a public instrument; therefore, it conveyed no title.
Background
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
Primary Holding
The Supreme Court remanded the consolidated cases to a Special Division of the Court of Appeals to conduct further proceedings and factually determine which of the contending parties' titles, if any, are validly derived from the genuine Original Certificate of Title No. 994 registered on May 3, 1917, and to resolve other factual issues crucial to determining rightful land ownership. Titles purportedly derived from a non-existent OCT No. 994 dated April 19, 1917 are declared void.
Background
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
Primary Holding
The respondents, Heirs of Agrifina Rañon, validly acquired ownership of the subject property through extraordinary acquisitive prescription because they demonstrated continuous, peaceful, public, notorious, uninterrupted, and adverse possession in the concept of an owner for over thirty years.
Background
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
Primary Holding
The Supreme Court partially granted the petition, affirming the Court of Appeals' decision to reinstate the original writ of preliminary injunction (maintaining status quo). However, the Supreme Court recognized the petitioner's need for temporary easement for construction purposes under Article 656 of the Civil Code and remanded the case to the trial court to determine the proper indemnity for this temporary right of way. The installation of power lines was deemed a permanent easement not covered by the temporary easement provisions.
Background
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
Primary Holding
The Supreme Court held that the agreement was a contract to sell, and because the vendee failed to fully pay the purchase price, ownership of the property did not transfer to her. Consequently, the action for quieting of title filed by the vendors was deemed proper and not prescribed as they remained in possession and legal owners of the property.
Background
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
Primary Holding
The Supreme Court set aside the Court of Appeals' decision and remanded the case to the trial court to order a joint survey by NHA and MSBF to determine the precise metes and bounds of the seven-hectare usufruct granted to MSBF, ensuring contiguity and inclusion of MSBF's major existing facilities as much as possible within that area, while also ensuring MSBF respects the seven-hectare limit and vacates any area exceeding it.
Background
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
Primary Holding
The petition is granted. The decisions of the Court of Appeals and the Regional Trial Court are reversed and set aside. The complaint of the respondent is dismissed. The respondent failed to implead indispensable parties and failed to prove his claim of ownership by preponderance of evidence sufficient to overcome the petitioners' Torrens title.
Background
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
Primary Holding
The Supreme Court denied the Motion for Reconsideration and Motion to Remand but granted the Motion for Clarification by rectifying specific typographical and clerical errors within its previous Decision dated February 12, 1997, ultimately granting the Petition for Review and reinstating the decision of the Court of First Instance.
Background
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
Primary Holding
A lessee of land who constructs improvements thereon is not considered a builder in good faith under Articles 448 and 546 of the Civil Code and therefore does not have the right to retain possession until reimbursed for the full value of the improvements. The rights of a lessee regarding improvements are governed by Article 1678 of the Civil Code, which limits reimbursement to one-half of the improvement's value at the lessor's option and does not grant a right of retention.
Background
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
Primary Holding
The Supreme Court held that while the revocation of the donation was valid due to the donee's ingratitude through forgery, the petitioner-spouses were purchasers in good faith. Consequently, the deed of absolute sale to the petitioners and their title were upheld, but the fraudulent donee was held liable for damages to the original donor.
Background
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
Primary Holding
The easement of right-of-way in favor of the public was validly constituted and was not extinguished by merger when Bio Hong Trading Co., Inc. acquired the property; therefore, Bio Hong must respect and maintain the easement, removing any obstructions.
Background
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
Primary Holding
The dried-up portion of Estero Calubcub is public land, not private property of the riparian owners, because its drying up was caused by human intervention and not a natural change in the course of the waters.
Background
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
Primary Holding
The owner of the land along the margin nearest to an island formed in a non-navigable and non-floatable river has a better right to the island than those in actual possession of it, based on the principle of riparian ownership and accretion as provided in Article 465 of the Civil Code.
Background
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
Primary Holding
Forest lands and national parks are not subject to private appropriation; Spanish titles are not valid proof of ownership for unregistered lands after Presidential Decree No. 892.
Background
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
Primary Holding
Article 448 of the Civil Code can apply to resolve disputes between former co-owners after partition, concerning constructions made in good faith that encroach on another co-owner's allocated portion.
Background
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
Primary Holding
A possessor who initially acquired property based on a court decision, even if later reversed, is considered a possessor in good faith until they are actually aware of a defect in their title. Bad faith is personal and not transmissible to heirs unless they have personal knowledge of the flaw. Good faith is presumed, and the burden of proving bad faith lies with the one alleging it.
Background
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
Primary Holding
The Supreme Court held that the land acquired by Acme Plywood from the Infiels in 1962 was already private land by operation of law due to the Infiels' immemorial possession, and thus Acme Plywood, as a successor-in-interest, had a registrable title despite being a corporation and despite the 1973 Constitution’s restrictions, because the right vested prior to the 1973 Constitution.
Background
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
Primary Holding
Possession of forest lands, regardless of duration, cannot ripen into private ownership. Forest lands remain in the public domain and are not subject to registration for private individuals unless there is a positive act from the government declassifying them as agricultural or disposable land.
Background
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
Primary Holding
Narvaez is guilty of two counts of homicide, not murder, due to incomplete self-defense and mitigating circumstances. His sentence is reduced to four months of arresto mayor, and he is ordered to indemnify the heirs of the deceased with a reduced amount of damages, leading to his immediate release given his lengthy pre-trial detention.
Background
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
Primary Holding
The Original Certificate of Title held by the Vallartas is valid and superior, while the Free Patent Title held by the Azarcons is declared null and void and ordered cancelled.
Background
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
Primary Holding
A summary judgment was correctly rendered because the defendants-appellants violated the conditions of a registered easement of drainage and failed to demonstrate a genuine issue of material fact that would necessitate a full trial. Furthermore, any prescriptive easement of light and view was extinguished by the registration of the servient estate under the Torrens System without such easement being annotated.
Background
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
Primary Holding
A house constructed on rented land can be validly constituted as personal property and subject to a chattel mortgage if the parties to the contract agree to treat it as such. Furthermore, the mortgagor is not obligated to pay rent to the purchaser during the one-year redemption period following an extrajudicial foreclosure sale, unless the purchaser legally obtains possession through proper court procedures and posting of a bond.
Background
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
Primary Holding
Republic Act 3039 is constitutional insofar as it transfers properties of the former Zamboanga province used for governmental purposes (public properties) to Zamboanga City without compensation, but unconstitutional for properties not used for such purposes (patrimonial properties), as the latter requires due process and just compensation for valid transfer.
Background
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
Primary Holding
Paraphernal property of the wife is not liable for the debts of the husband, even if a conjugal house is built on it, if the land was exclusively owned by the wife prior to the construction and debt incurrence.
Background
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
Primary Holding
A house constructed on leased land is considered immovable property, not personal property, for purposes of attachment and execution, regardless of agreements between private parties treating it as chattel. Therefore, the rules for attaching immovable property must be followed.
Background
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
Primary Holding
An invalid donation of immovable property, while not transferring title, can serve as a valid basis for acquisitive prescription if accompanied by open, continuous, adverse, and public possession in the concept of owner for the period required by law.
Background
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
Primary Holding
The original owner of a movable property, who was unlawfully deprived of it due to fraud, has a better right to recover possession than a subsequent purchaser, even if the latter acted in good faith and for value.
Background
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
Primary Holding
Machinery installed in a leased building by the lessee for its own industry, which is movable by nature and not intended to be a permanent fixture belonging to the landowner, especially when the lease agreement explicitly excludes machineries from improvements passing to the lessor, retains its character as personal property and is therefore subject to chattel mortgage and execution as such.
Background
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
Primary Holding
Standing sugar cane, when produced by annual crops and yearly labor, is considered personal property and is therefore not subject to redemption as real property under the provisions of the Civil Code regarding redemption of real estate.
Background
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
Primary Holding
The Supreme Court upheld the lower court's judgment, ruling that the plaintiffs' action for partition was barred by prescription because the defendants and their predecessors had been in continuous, adverse possession of the coconut land for over thirty years, under claim of ownership.
Background
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
Primary Holding
The donation made by Da. Petrona Reyes to Leonardo Osorio of her share in her deceased husband's inheritance, even before formal adjudication, is valid because she had a vested right to the inheritance at the time of donation, and such inheritance is not considered "future property" in the prohibitive sense of Article 635 of the Civil Code.
Background
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
Primary Holding
The municipal council members are held jointly and severally liable for damages sustained by Marcos Mendoza due to the unlawful rescission of his ferry lease contract because their actions were not in good faith and were not a mere error in judgment, but a clear disregard of Mendoza's contractual rights for no valid reason.
Background
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
Primary Holding
In cases of double registration under the Torrens system, the certificate of title earlier in date prevails over the later one; registered title holders are not obligated to continuously monitor subsequent land registration proceedings to protect their already registered title.
Background
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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