Supapo v. De Jesus Case Digest

G.R. No. 198356

April 20, 2015

Facts:

• Spouses Supapo owned a parcel of land in Quezon City valued at Php39,980 (according to the Declaration of Real Property Value or tax declaration).
• The spouses do not reside in the lot, but they visit it at least twice a year.
• In 1992, they discovered that there were 2 houses built therein. It was without their consent or knowledge.
• They filed a criminal case against the Spouses de Jesus and Macario, who were the owners of the houses.
  • They filed this under PD 772 or the Anti-Squatting Law.
• While the case was pending, however, Congress enacted RA 8368 “An Act Repealing PD 772”.
  • Thus, the criminal case was dismissed.
  • The dismissal became final in 1999.
• Even though the dismissal became final, the Spouses Supapo moved for the execution of the respondents’ civil liability.
  • The RTC granted the motion.
  • But the CA reversed the RTC, saying that with the repeal of the Anti-Squatting Law, the respondents’ criminal and civil liabilities were extinguished.
• Thereafter, the Spouses Supapo filed a complaint for accion publiciana.
  • Respondents contended they could not do this because
    • There is another action pending between the same parties
    • The complaint for accion publiciana is barred by the statute of limitations and
    • The Spouses Supapo’s cause of action is barred by prior judgment
• MeTC ruled against respondents.
• The RTC agreed with respondents on two grounds:
  • The action has prescribed
  • Accion publiciana falls within the exclusive jurisdiction of the RTC
    • It held that in an action where the only issue is possession, the MeTC has jurisdiction is the action for forcible entry or unlawful detainer is filed within 1 year from the time to demand to vacate was made. Otherwise, it should be filed before the RTC.
    • It held that the action was filed beyond the 10-year prescriptive period under Art 555 of the Civil Code.

Issues:

1. Has the action prescribed?
2. Is the complaint for accion publiciana barred by res judicata?

Ruling:

1. No.

In a long line of cases, we have consistently ruled that lands covered by a title cannot be acquired by prescription or adverse possession. We have also held that a claim of acquisitive prescription is baseless when the land involved is a registered land because of Article 1126 of the Civil Code in relation to Act 496 [now, Section 47 of Presidential Decree (PD) No. 152950].

The Spouses Supapo (as holders of the TCT) enjoy a panoply of benefits under the Torrens system. The most essential insofar as the present case is concerned is Section 47 of PD No. 1529 which states:

Section 47. Registered land not subject to prescriptions. No title to registered land in derogation of the title of the registered owner shall be acquired by prescription or adverse possession.

In addition to the imprescriptibility, the person who holds a Torrens Title over a land is also entitled to the possession thereof.

With respect to laches

The ground on laches is evidentiary in nature and cannot be established by mere allegations in the pleadings.60 In other words, the party alleging laches must adduce in court evidence proving such allegation. This Court not being a trier of facts cannot rule on this issue; especially so since the lower courts did not pass upon the same.

• No.

Res judicata embraces two concepts:

A. bar by prior judgment

• Rule 39, Section 47(b) of the Rules of Civil Procedure
• means that when a right or fact had already been judicially tried on the merits and determined by a court of competent jurisdiction, the final judgment or order shall be conclusive upon the parties and those in privity with them and constitutes an absolute bar to subsequent actions involving the same claim, demand or cause of action.

B.conclusiveness of judgment

• Rule 39, Section 47(c)

Elements of Res Judicata (Bar by Prior Judgment)

1. The former judgment or order must be final.
2. It must be a judgment on the merits.
3. It must have been rendered by a court having jurisdiction over the subject matter and the parties.
4. There must be between the first and second actions, identity of parties, subject matter, and cause of action.

In this case, requisites 1 to 3 are present, but the fourth is not.

Why?

• There is no identity of parties.
  • The party in the criminal case is the People of the Philippines. The party in the present case is the Spouses Supapo.
• There is no identity of subject matter.
  • The criminal case involves the prosecution of a crime under the Anti-Squatting Law while the accion publiciana is an action to recover possession of the subject property.
• There is no identity of causes of action.
  • The people of the Philippines filed the criminal case to protect and preserve governmental interests by prosecuting persons who violated the statute. The Spouses Supapo filed the accion publiciana to protect their proprietary interests over the subject property and recover its possession.

Notes on the Jurisdiction

• Under BP 129
  • the jurisdiction of the RTC over actions involving title to or possession of real property is plenary.
• RA No. 7691
• divested the RTC of a portion of its jurisdiction and granted the Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts the exclusive and original jurisdiction to hear actions where the assessed value of the property does not exceed Twenty Thousand Pesos (P20,000.00), or Fifty Thousand Pesos (P50,000.00), if the property is located in Metro Manila.
  • Remember that the property in this case is valued at Php39,980 and is located in Quezon City, which is a part of Metro Manila.

Thus, the MeTC acquired jurisdiction here contrary to what the RTC said.