Realty v. Sta. Lucia Realty
REITERATIONFacts
The Antecedents: The Republic of the Philippines filed a complaint to nullify Decree No. 6145 and TCT No. 23377 covering "Hacienda Angono." The trial court and CA initially declared the decree and title genuine. This Court, in Republic v. CA, affirmed the authenticity of Decree No. 6145 and TCT No. 23377 but also recognized the superior rights of "bona fide occupants with registered titles" and "bona fide occupants therein with length of possession which had ripened to ownership, the latter to be determined in an appropriate proceeding." This recognition was based on the waiver by the original title holders of their rights in favor of these occupants. Procedural History: Petitioner E. Rommel Realty and Development Corporation, as subrogee of Guido, et al., obtained a writ of possession. Respondent Sta. Lucia Realty Development Corporation, owner-developer of Greenridge Executive Village, was in possession of a 29,999 sq. m. lot within Hacienda Angono. Respondent filed a motion to quash the writ of possession, claiming it was a bona fide occupant whose possession, through predecessors-in-interest (heirs of de la Cruz), had ripened into ownership. The RTC denied this motion, stating respondent should ventilate its claim in a separate proceeding. The Court of Appeals, however, granted respondent's petition for certiorari and prohibition, nullifying the RTC's order and the alias writ of possession, holding that while respondent's rights needed a separate proceeding, the RTC, in executing the judgment, deprived respondent of its right to present evidence. The Petition: Petitioner seeks review of the CA decision, arguing it was entitled to the writ of possession as respondent failed to prove its claim in an appropriate proceeding as contemplated by the Republic v. CA decision.
Issue(s)
Whether petitioner was entitled to a writ of possession over the 29,999 sq. m. lot possessed by respondent, considering the rights of bona fide occupants. Whether respondent had proven its claim of bona fide occupancy with possession ripened into ownership in an appropriate proceeding, thereby establishing a superior right to possession.
Ruling
The petition is denied. The Court of Appeals correctly nullified the writ of possession of the disputed property.
Ratio Decidendi
On the entitlement to a writ of possession and proof of claim: The Court affirmed the CA's ruling that the writ of possession should be nullified. While the Court in Republic v. CA recognized the ownership rights of Guido, et al. over the land covered by TCT No. 23377, it simultaneously imposed a crucial limitation: the superior rights of bona fide occupants with registered titles and those whose possession had ripened into ownership, to be determined in an appropriate proceeding. Petitioner, as subrogee, was bound by this limitation. The Court found that respondent had indeed proven its claim in an appropriate proceeding, specifically L.R.C. No. 049-B, initiated by its predecessors-in-interest, the heirs of de la Cruz. In this proceeding, it was established that the heirs' possession had ripened into ownership as of March 29, 1976. This ruling inured to the benefit of the respondent as the purchaser of the property. On the nature of respondent's possession and right to possession: Although the records did not show that respondent obtained a certificate of title, the right of ownership of its predecessors-in-interest had been recognized. As the purchaser, respondent acquired the attributes of ownership, including the right to possession (jus possidendi). Respondent was in actual possession of the property before the writ of possession was implemented and possessed it as owner. Therefore, respondent could rightfully assert its right of possession, which is a fundamental attribute of ownership under Article 428 of the New Civil Code. The Court reiterated that the superior rights acknowledged in Republic v. CA could be rightfully claimed by the respondent, and the CA correctly nullified petitioner's writ of possession concerning the property in respondent's possession.
Main Doctrine
A writ of possession issued pursuant to a final and executory judgment may be nullified if the party against whom it is enforced can prove, in an appropriate proceeding, that their possession of the property has ripened into ownership, thereby entitling them to superior rights acknowledged in the original decision.