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OCHOA v. MAURO APETA

FACTS:

The case involves a dispute over Lot No. 1580 in Biñan, Laguna. The petitioners and their predecessors-in-interest have occupied the lot since 1910 and have built their houses and apartment building on the property. In 1982, the respondents claimed to be the true owners of Lot No. 1580. In 1988, they filed a complaint for recovery of possession and damages against the petitioners. The Regional Trial Court (RTC) rendered a decision in favor of the respondents, declaring them as the true and lawful owners of Lot No. 1580 and ordering the petitioners to vacate the property. The Court of Appeals affirmed the RTC decision, prompting the petitioners to file a petition for review on certiorari before the Supreme Court. The petitioners argue that they are the owners of Lot No. 1580 and that the respondents' action is barred by prescription. The Supreme Court ruled that questions of ownership are factual in nature and cannot be raised in a petition for review on certiorari. They also held that no title to registered land can be acquired by adverse possession against the registered owner. The Court affirmed the Court of Appeals decision, with the modification that the respondents have the option to pay for the houses and apartment building constructed by the petitioners or oblige the petitioners to pay the price of the lot.

ISSUES:

  1. Whether the claim of petitioners that they are the owners of Lot No. 1580 can be raised in a petition for review on certiorari.

  2. Whether respondents' action for recovery of possession has been barred by prescription.

RULING:

  1. The claim of petitioners that they are the owners of Lot No. 1580 cannot be raised in a petition for review on certiorari. Only questions of law may be raised in such a petition. The issue raised by petitioners requires a review of the evidence presented by the parties, which is considered a question of fact and is beyond the jurisdiction of the Supreme Court.

  2. The action of respondents for recovery of possession has not been barred by prescription. No title to registered land in derogation to that of the registered owner shall be acquired by prescription or adverse possession. Prescription cannot be allowed against the hereditary successors of the registered owner, as they are merely the continuation of the personality of their predecessor-in-interest.

PRINCIPLES:

  • In an appeal via a petition for review on certiorari, only questions of law may be raised. The Supreme Court is not a trier of facts unless certain exceptions are met.

  • No title to registered land in derogation to that of the registered owner shall be acquired by prescription or adverse possession.

  • Prescription cannot be allowed against the hereditary successors of the registered owner.

  • The owner of the land on which anything has been built, sown, or planted in good faith has the right to appropriate the works or oblige the builder to pay the price of the land. The choice belongs to the landowner.

  • Only the possessor in good faith may retain the thing until reimbursed for necessary expenses.