Ochoa v. Apeta
REITERATIONFacts
The Antecedents: Petitioners and their predecessors-in-interest have occupied Lot No. 1580, covered by TCT No. T-40624, since 1910, building houses and an apartment building thereon. Respondents Mauro Apeta and Apolonia Almazan discovered in May 1982 that they were the true owners of Lot No. 1580, which is covered by Certificate of Title No. RT-599 (10731). Procedural History: On January 22, 1988, respondents filed a complaint for recovery of possession and damages against petitioners. Petitioners denied the allegations, claiming ownership based on TCT No. T-40624. A commissioned resurvey by Engr. Romulo Unciano revealed that Lot No. 1580, occupied by petitioners, was registered in the name of respondents' predecessor-in-interest, Margarita Almada, and that TCT No. T-40624 covered Lot No. 1581, registered in the name of petitioners' predecessor-in-interest, Servillano Ochoa. The Regional Trial Court (RTC), Branch 24, Biñan, Laguna, rendered a Decision on March 24, 1995, in favor of respondents, declaring them the lawful owners of Lot No. 1580 and ordering petitioners to deliver possession and remove their structures. The Court of Appeals (CA) affirmed the RTC Decision on September 8, 2000, and denied petitioners' motion for reconsideration on November 20, 2000. The Petition: Petitioners contend that Lot No. 1580 belongs to them and that respondents' action is barred by prescription.
Issue(s)
Whether the action for recovery of possession is barred by prescription. Whether petitioners are the true and lawful owners of Lot No. 1580. Whether petitioners were builders in good faith.
Ruling
The petition is DENIED. The assailed Decision and Resolution of the Court of Appeals are AFFIRMED with MODIFICATION. Respondents have the option to pay for the houses and apartment building constructed by petitioners and their predecessors-in-interest on Lot No. 1580; or to oblige petitioners to pay the price of the lot in an amount not more than the value of the said improvements.
Ratio Decidendi
On the issue of prescription: The Court reiterated the well-established principle that no title to registered land in derogation to that of the registered owner shall be acquired by prescription or adverse possession. This principle applies equally to hereditary successors who step into the shoes of the decedent. Therefore, respondents' action for recovery of possession was not barred by prescription. The Court emphasized that prescription cannot be invoked against the registered owner of the land. The findings of the lower courts, supported by the resurvey, clearly established respondents' ownership. Thus, petitioners' claim of ownership through adverse possession was correctly dismissed. On the issue of ownership: The Court held that the issue of ownership between the parties required a review of evidence, which is generally outside the scope of a petition for review on certiorari under Rule 45. However, the Court noted that it may review factual findings if they are contradictory or based on a misapprehension of facts. In this case, the factual findings of the RTC and CA, particularly those based on the resurvey conducted by Engr. Romulo Unciano, were consistent and supported by evidence. These findings established that respondents are the true and lawful owners of Lot No. 1580. The Court affirmed these findings, stating that it is not a trier of facts and will generally defer to the lower courts' factual determinations when supported by evidence. On the issue of good faith: The Court determined that petitioners and their predecessors-in-interest were builders in good faith. Good faith was defined as an honest belief in the validity of one's right, the absence of malice, and the absence of design to defraud or seek an unconscionable advantage. Applying these parameters, the Court found that petitioners genuinely believed they owned Lot No. 1580 because it was covered by their TCT No. T-40624. Consequently, the provisions of Article 448 of the Civil Code were applied. This article grants the landowner the option to either appropriate the improvements by paying indemnity or oblige the builder to pay the price of the land. The Court modified the ruling to give respondents this option, aligning with the principle of accession where the accessory follows the principal.
Main Doctrine
No title to registered land in derogation to that of the registered owner shall be acquired by prescription or adverse possession. The owner of the land on which anything has been built, sown or planted in good faith shall have the right to appropriate as his own the works, sowing or planting, after payment of the indemnity provided for in Articles 546 and 548, or to oblige the one who built or planted to pay the price of the land.