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GR No. 191101

2014-10-01

SPS. MARIO OCAMPO v. HEIRS OF BERNARDINO U. DIONISIO

REYES, J.

Further, it is settled that a Torrens Certificate of Title is indefeasible and binding upon the whole world unless and until it has been nullified by a court of competent jurisdiction. Under existing statutory and decisional law, the power to pass upon the validity of such certificate of title at the first instance properly belongs to the Regional Trial Courts in a direct proceeding for cancellation of title.[26] Accordingly, the petitioners may not assail the validity of the issuance of OCT No. M-4559 in the name of Dionisio in their answer to the complaint filed by the respondents for recovery of possession of the subject property; it is a collateral attack to the validity of OCT No. M-4559, which the RTC and the CA aptly disregarded.

GR No. 174004

2013-10-09

VIRGILIO G. CAGATAO v. GUILLERMO ALMONTE

MENDOZA, J.

Although the CA correctly ruled that the transfer from Gatchalian to Manzulin was invalid, the existence of a valid Torrens title in the name of Carlos which has remained unchallenged before the proper courts has made irrelevant the issue of whether Gatchalian and his successors-in-interest should have retained ownership over the property. This is pursuant to the principle that a Torrens title is irrevocable and its validity can only be challenged in a direct proceeding. The purpose of adopting a Torrens System in our jurisdiction is to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized. This is to avoid any possible conflicts of title that may arise by giving the public the right to rely upon the face of the Torrens title and dispense with the need of inquiring further as to the ownership of the property.[24] Hence, a Torrens certificate of title is indefeasible and binding upon the whole world unless it is nullified by a court of competent jurisdiction in a direct proceeding for cancellation of title.[25]

GR No. 183822

2012-01-18

RUBEN C. CORPUZ v. SPS. HILARION AGUSTIN AND JUSTA AGUSTIN

SERENO, J.

Petitioner cites Jacinto Co v. Rizal Militar, et al.,[18] which has facts and legal issues identical to those of the instant case. The petitioner therein filed an unlawful detainer case against the respondents over a disputed property. He had a Torrens title thereto, while the respondents as actual occupants of the property claimed ownership thereof based on their unregistered Deeds of Sale. The principal issue was who between the two parties had the better right to possess the subject property.

GR No. 152423

2010-12-15

SPS. MARCOS R. ESMAQUEL AND VICTORIA SORDEVILLA v. MARIA COPRADA

PERALTA, J.

In Rodriguez v. Rodriguez,[16] citing the case of Co v. Militar,[17] the Court held that: [T]he Torrens System was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized.

GR No. 172447

2009-09-18

IGLESIA EVANGELICA METODISTA EN LAS ISLAS FILIPINAS v. NATANAEL B. JUANE

CHICO-NAZARIO, J.

An action for reconveyance or accion reivindicatoria has no effect and can exist at the same time as ejectment cases involving the same property.[9] This is because the only issue to be resolved in an unlawful detainer case is physical or material possession of the property involved, independent of any claim of ownership by any of the parties involved.[10] Ejectment cases are designed to summarily restore physical possession to one who has been illegally deprived of such possession, without prejudice to the settlement of the parties' opposing claims of juridical possession in appropriate proceedings.[11] The question of ownership may only be provisionally ruled upon for the sole purpose of determining who is entitled to possession de facto.[12]

GR No. 175720

2007-09-11

CRESENCIANA TUBO RODRIGUEZ v. EVANGELINE RODRIGUEZ

YNARES-SANTIAGO, J.

Further, in Co v. Militar,[20] it was held that:[T]he Torrens System was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized.

GR No. 175720

2007-09-11

CRESENCIANA TUBO RODRIGUEZ v. EVANGELINE RODRIGUEZ

YNARES-SANTIAGO, J.

Further, in Co v. Militar,[20] it was held that:[T]he Torrens System was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized.

GR NO. 159292

2007-07-12

SPS. RICHARD B. PASCUAL AND CRISTINA D. PASCUAL v. SPS. REYNALDO P. CORONEL AND ASUNCION MALIG CORONEL

NACHURA, J.

Even if we sustain the petitioners' arguments and rule that the deeds of sale are valid contracts, it would still not bolster the petitioners' case. In a number of cases, the Court had upheld the registered owners' superior right to possess the property. In Co v. Militar,[25] the Court was confronted with a similar issue of which between the certificate of title and an unregistered deed of sale should be given more probative weight in resolving the issue of who has the better right to possess. There, the Court held that the court a quo correctly relied on the transfer certificate of title in the name of petitioner, as opposed to the unregistered deeds of sale of the respondents. The Court stressed therein that the Torrens System was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized.[26]

GR NO. 130316

2007-01-24

ERNESTO V. YU v. BALTAZAR PACLEB

CORONA, J.

Most important, the title of the land in question (TCT No. T-118375) remained in the name of respondent.[25] "As the registered owner, petitioner had a right to the possession of the property, which is one of the attributes of ownership."[26] The Civil Code states:Art. 538. Possession as a fact cannot be recognized at the same time in two different personalities except in the cases of co-possession. Should a question arise regarding the fact of possession, the present possessor shall be preferred; if there are two possessors, the one longer in possession; if the dates of the possession are the same, the one who presents a title; and if all these conditions are equal, the thing shall be placed in judicial deposit pending determination of its possession or ownership through proper proceedings. In view of the evidence establishing respondent's continuing possession of the subject property, petitioners' allegation that respondent deprived them of actual possession by means of force, intimidation and threat was clearly untenable. In Gaza v. Lim, we held that:

GR NO. 158227

2005-10-19

KEPPEL BANK PHILIPPINES v. PHILIP ADAO

QUISUMBING, J.

Considering that respondent failed to discharge the burden of proving payment, he cannot claim ownership of the property and his possession thereof was by mere tolerance. His continued possession became unlawful upon the owner's demand to vacate the property.[20] We stress, however, that this adjudication, is only a provisional determination of ownership for the purpose of settling the issue of possession,[21] and does not bar or prejudice an action between the same parties involving title to the property.[22]

GR NO. 156581

2005-09-30

VICTORIA R. ARAMBULO v. EMERENCIANA R. GUNGAB

QUISUMBING, J.

The sole issue for resolution in an unlawful detainer case is physical or material possession.[17] But even if there was a claim of juridical possession or an assertion of ownership by the defendant, the MeTC may still take cognizance of the case. All that the trial court can do is to make an initial determination of who is the owner of the property so that it can resolve who is entitled to its possession absent other evidence to resolve ownership.[18] Courts in ejectment cases decide questions of ownership only as it is necessary to decide the question of possession. The reason for this rule is to prevent the defendant from trifling with the summary nature of an ejectment suit by the simple expedient of asserting ownership over the disputed property.[19]

GR NO. 152978

2005-03-04

ANICIA U. TECSON v. DANTE GUTIERREZ

QUISUMBING, J.

It is settled that the only issue for resolution in ejectment suits is the physical or material possession of the property involved, independent of any claim of ownership by any of the party litigants.[18] In forcible entry and unlawful detainer cases, even if the defendant raises the question of ownership in his pleadings and the question of possession cannot be resolved without deciding the issue of ownership, the MTC, nonetheless, has the undoubted competence to provisionally resolve the issue of ownership for the sole purpose of determining the issue of possession.[19]

GR NO. 160014

2005-02-18

ROMEO MENDOZA v. CA

PUNO, J.

An action for unlawful detainer may be filed when possession by a landlord, vendor, vendee or other person of any land or building is unlawfully withheld after the expiration or termination of the right to hold possession by virtue of a contract, express or implied.[7] The only issue to be resolved in an unlawful detainer case is physical or material possession of the property involved, independent of any claim of ownership by any of the parties involved.[8]

GR Nos. 154391-92

2004-09-30

SPS. ISMAEL AND TERESITA MACASAET v. SPS. VICENTE AND ROSARIO MACASAET

PANGANIBAN, J.

Who is entitled to the physical or material possession of the premises? At the outset, we stress that this is the main issue in ejectment proceedings.[27] In the present case, petitioners failed to justify their right to retain possession of the subject lots, which respondents own. Since possession is one of the attributes of ownership,[28] respondents clearly are entitled to physical or material possession.

	GR No. 191101 2014-10-01	SPS. MARIO OCAMPO v. HEIRS OF BERNARDINO U. DIONISIO REYES, J.
Further, it is settled that a Torrens Certificate of Title is indefeasible and binding upon the whole world unless and until it has been nullified by a court of competent jurisdiction. Under existing statutory and decisional law, the power to pass upon the validity of such certificate of title at the first instance properly belongs to the Regional Trial Courts in a direct proceeding for cancellation of title.[26] Accordingly, the petitioners may not assail the validity of the issuance of OCT No. M-4559 in the name of Dionisio in their answer to the complaint filed by the respondents for recovery of possession of the subject property; it is a collateral attack to the validity of OCT No. M-4559, which the RTC and the CA aptly disregarded.
	GR No. 174004 2013-10-09	VIRGILIO G. CAGATAO v. GUILLERMO ALMONTE MENDOZA, J.
Although the CA correctly ruled that the transfer from Gatchalian to Manzulin was invalid, the existence of a valid Torrens title in the name of Carlos which has remained unchallenged before the proper courts has made irrelevant the issue of whether Gatchalian and his successors-in-interest should have retained ownership over the property. This is pursuant to the principle that a Torrens title is irrevocable and its validity can only be challenged in a direct proceeding. The purpose of adopting a Torrens System in our jurisdiction is to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized. This is to avoid any possible conflicts of title that may arise by giving the public the right to rely upon the face of the Torrens title and dispense with the need of inquiring further as to the ownership of the property.[24] Hence, a Torrens certificate of title is indefeasible and binding upon the whole world unless it is nullified by a court of competent jurisdiction in a direct proceeding for cancellation of title.[25]
	GR No. 183822 2012-01-18	RUBEN C. CORPUZ v. SPS. HILARION AGUSTIN AND JUSTA AGUSTIN SERENO, J.
Petitioner cites Jacinto Co v. Rizal Militar, et al.,[18] which has facts and legal issues identical to those of the instant case. The petitioner therein filed an unlawful detainer case against the respondents over a disputed property. He had a Torrens title thereto, while the respondents as actual occupants of the property claimed ownership thereof based on their unregistered Deeds of Sale. The principal issue was who between the two parties had the better right to possess the subject property.
	GR No. 152423 2010-12-15	SPS. MARCOS R. ESMAQUEL AND VICTORIA SORDEVILLA v. MARIA COPRADA PERALTA, J.
In Rodriguez v. Rodriguez,[16] citing the case of Co v. Militar,[17] the Court held that: [T]he Torrens System was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized.
	GR No. 172447 2009-09-18	IGLESIA EVANGELICA METODISTA EN LAS ISLAS FILIPINAS v. NATANAEL B. JUANE CHICO-NAZARIO, J.
An action for reconveyance or accion reivindicatoria has no effect and can exist at the same time as ejectment cases involving the same property.[9] This is because the only issue to be resolved in an unlawful detainer case is physical or material possession of the property involved, independent of any claim of ownership by any of the parties involved.[10] Ejectment cases are designed to summarily restore physical possession to one who has been illegally deprived of such possession, without prejudice to the settlement of the parties' opposing claims of juridical possession in appropriate proceedings.[11] The question of ownership may only be provisionally ruled upon for the sole purpose of determining who is entitled to possession de facto.[12]
	GR No. 175720 2007-09-11	CRESENCIANA TUBO RODRIGUEZ v. EVANGELINE RODRIGUEZ YNARES-SANTIAGO, J.
Further, in Co v. Militar,[20] it was held that:[T]he Torrens System was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized.
	GR No. 175720 2007-09-11	CRESENCIANA TUBO RODRIGUEZ v. EVANGELINE RODRIGUEZ YNARES-SANTIAGO, J.
Further, in Co v. Militar,[20] it was held that:[T]he Torrens System was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized.
	GR NO. 159292 2007-07-12	SPS. RICHARD B. PASCUAL AND CRISTINA D. PASCUAL v. SPS. REYNALDO P. CORONEL AND ASUNCION MALIG CORONEL NACHURA, J.
Even if we sustain the petitioners' arguments and rule that the deeds of sale are valid contracts, it would still not bolster the petitioners' case. In a number of cases, the Court had upheld the registered owners' superior right to possess the property. In Co v. Militar,[25] the Court was confronted with a similar issue of which between the certificate of title and an unregistered deed of sale should be given more probative weight in resolving the issue of who has the better right to possess. There, the Court held that the court a quo correctly relied on the transfer certificate of title in the name of petitioner, as opposed to the unregistered deeds of sale of the respondents. The Court stressed therein that the Torrens System was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized.[26]
	GR NO. 130316 2007-01-24	ERNESTO V. YU v. BALTAZAR PACLEB CORONA, J.
Most important, the title of the land in question (TCT No. T-118375) remained in the name of respondent.[25] "As the registered owner, petitioner had a right to the possession of the property, which is one of the attributes of ownership."[26] The Civil Code states:Art. 538. Possession as a fact cannot be recognized at the same time in two different personalities except in the cases of co-possession. Should a question arise regarding the fact of possession, the present possessor shall be preferred; if there are two possessors, the one longer in possession; if the dates of the possession are the same, the one who presents a title; and if all these conditions are equal, the thing shall be placed in judicial deposit pending determination of its possession or ownership through proper proceedings. In view of the evidence establishing respondent's continuing possession of the subject property, petitioners' allegation that respondent deprived them of actual possession by means of force, intimidation and threat was clearly untenable. In Gaza v. Lim, we held that:
	GR NO. 158227 2005-10-19	KEPPEL BANK PHILIPPINES v. PHILIP ADAO QUISUMBING, J.
Considering that respondent failed to discharge the burden of proving payment, he cannot claim ownership of the property and his possession thereof was by mere tolerance. His continued possession became unlawful upon the owner's demand to vacate the property.[20] We stress, however, that this adjudication, is only a provisional determination of ownership for the purpose of settling the issue of possession,[21] and does not bar or prejudice an action between the same parties involving title to the property.[22]
	GR NO. 156581 2005-09-30	VICTORIA R. ARAMBULO v. EMERENCIANA R. GUNGAB QUISUMBING, J.
The sole issue for resolution in an unlawful detainer case is physical or material possession.[17] But even if there was a claim of juridical possession or an assertion of ownership by the defendant, the MeTC may still take cognizance of the case. All that the trial court can do is to make an initial determination of who is the owner of the property so that it can resolve who is entitled to its possession absent other evidence to resolve ownership.[18] Courts in ejectment cases decide questions of ownership only as it is necessary to decide the question of possession. The reason for this rule is to prevent the defendant from trifling with the summary nature of an ejectment suit by the simple expedient of asserting ownership over the disputed property.[19]
	GR NO. 152978 2005-03-04	ANICIA U. TECSON v. DANTE GUTIERREZ QUISUMBING, J.
It is settled that the only issue for resolution in ejectment suits is the physical or material possession of the property involved, independent of any claim of ownership by any of the party litigants.[18] In forcible entry and unlawful detainer cases, even if the defendant raises the question of ownership in his pleadings and the question of possession cannot be resolved without deciding the issue of ownership, the MTC, nonetheless, has the undoubted competence to provisionally resolve the issue of ownership for the sole purpose of determining the issue of possession.[19]
	GR NO. 160014 2005-02-18	ROMEO MENDOZA v. CA PUNO, J.
An action for unlawful detainer may be filed when possession by a landlord, vendor, vendee or other person of any land or building is unlawfully withheld after the expiration or termination of the right to hold possession by virtue of a contract, express or implied.[7] The only issue to be resolved in an unlawful detainer case is physical or material possession of the property involved, independent of any claim of ownership by any of the parties involved.[8]
	GR Nos. 154391-92 2004-09-30	SPS. ISMAEL AND TERESITA MACASAET v. SPS. VICENTE AND ROSARIO MACASAET PANGANIBAN, J.
Who is entitled to the physical or material possession of the premises? At the outset, we stress that this is the main issue in ejectment proceedings.[27] In the present case, petitioners failed to justify their right to retain possession of the subject lots, which respondents own. Since possession is one of the attributes of ownership,[28] respondents clearly are entitled to physical or material possession.

JACINTO V. CO v. RIZAL MILITAR