Pelaez Vda. de Tan v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns ownership and possession of a parcel of land. Gregorio Yrastorza initially owned four adjacent lots. He sold the first three lots to Atty. Jorge P. Tan, husband of petitioner Concepcion Pelaez Vda. de Tan and father of the other petitioners. The first lot, Lot No. ONE (1) of the Consolidation and Subdivision Plan of Cad. Lots 31 and 32 of Ormoc Cadastre, was purportedly sold with an area of 677 square meters, but its title (TCT No. 2899, later TCT No. 4020) indicated an area of 463 square meters. A portion of the Metro Theatre, built on this lot by the petitioners, encroached upon an adjacent lot (Lot I of Psd-177251) which Yrastorza later sold to the private respondents, Spouses Emeterio and Adelina Larrazabal. 2. Procedural History: Private respondents filed a complaint for Recovery of Ownership and Possession with a Petition for Issuance of a Writ of Preliminary Mandatory Injunction to recover the 214 square meters of their land occupied by the Metro Theatre's stage. The Regional Trial Court (RTC), Branch XII, Ormoc City, granted the injunction, concluding that the Deed of Sale between Yrastorza and Atty. Tan contained a clerical error regarding the area, and that the Larrazabals had a clear right to the 214 square meters based on their title. Petitioners appealed this decision to the Intermediate Appellate Court (IAC) via a special civil action for injunction, prohibition, and certiorari, seeking to annul the RTC's orders. The IAC dismissed the petition, affirming the RTC's findings that the petitioners' title only covered 463 square meters and that the private respondents were entitled to the disputed portion. 3. The Petition: The petitioners are before the Supreme Court on a petition for review on certiorari, assailing the decision of the Intermediate Appellate Court. They argue that the IAC erred in dismissing their special civil action and upholding the RTC's orders. The core of their argument revolves around the discrepancy in the area of the land sold by Yrastorza to Atty. Tan. Petitioners contend that the Deed of Sale accurately reflected the intended sale of 677 square meters, and that the titles issued subsequently contained errors. They seek to annul the orders of the respondent judge and the decision of the IAC, which they believe unjustly deprived them of their property rights.
Issue(s)
Whether the respondent judge committed grave abuse of discretion in issuing the writ of preliminary mandatory injunction. Whether the Deed of Absolute Sale, which stated an area of 677 sq. m., should prevail over the Transfer Certificates of Title which indicated an area of 463 sq. m. for the subject lot.
Ruling
The petition is dismissed for lack of merit. The assailed orders of the respondent judge are affirmed.
Ratio Decidendi
On the issue of grave abuse of discretion in issuing the writ of preliminary mandatory injunction: The Court found no reversible error in the orders of the respondent judge. The Intermediate Appellate Court (IAC) correctly observed that the Transfer Certificates of Title (TCT) in the names of the petitioners (TCT No. 4020, originating from TCT No. 2899) consistently stated an area of 463 square meters for Lot I. This contradicted the 677 square meters mentioned in the Deed of Absolute Sale. The IAC's conclusion that the respondent judge did not commit grave abuse of discretion in initially recognizing the private respondents' right over the disputed 214 square meters for the purpose of issuing the writ was therefore upheld. The issuance of the injunction was based on the apparent discrepancy between the deed and the titles, and the registered titles themselves, which are imprescriptible, clearly established the private respondents' right over the portion in question. On the conflict between the Deed of Sale and the Transfer Certificates of Title regarding the area of the land: The Court affirmed the principle that what defines a piece of land is not solely the area mentioned in its description but, more importantly, the boundaries laid down therein, as these enclose the land and indicate its limits. In this case, the identity of the land sold was Lot 1 of the Consolidated Lots 31 and 32, and its boundaries were sufficiently and certainly described in TCT No. 4020 (and its predecessor TCT No. 2899), which explicitly stated an area of 463 square meters. The Court reiterated that Gregorio Yrastorza could not have sold an area larger than what was stated in his title. Consequently, when TCT No. 2899 was cancelled and TCT No. 4020 was issued in the name of the vendee, Jorge S. Tan, it was only for the 463 square meters property. Furthermore, the Court emphasized the settled rule that titled property cannot be attacked collaterally; it can only be altered, modified, or cancelled in a direct proceeding in accordance with law. The discrepancy in the Deed of Sale was deemed a mistake in its drafting, and the registered titles were given precedence in determining the actual extent of the property conveyed.
Main Doctrine
The boundaries of a titled property, as indicated in the title, define its identity and limits, not merely the area mentioned. Titled property cannot be attacked collaterally and can only be altered, modified, or cancelled in a direct proceeding.