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CHARLIE T. LEE v. ROSITA DELA PAZ

FACTS:

This case involves a Petition for Review on Certiorari filed by petitioner Charlie T. Lee seeking the reversal of the Court of Appeals' decision and resolution. The Regional Trial Court had previously ruled in favor of respondent, ordering petitioner to vacate the portions of the property he occupied. The facts of the case are as follows:

On October 29, 1990, Gabriel Danga executed a notarized Transfer of Rights transferring all his rights, interest, and title over a parcel of agricultural land to respondent for the consideration of P150,000. Respondent filed an administrative case for the cancellation of the Order of Transfer of Homestead Rights. During an ocular inspection, it was observed that petitioner and several other persons occupied certain portions of the property.

Respondent filed a Complaint for Forcible Entry against petitioner. Petitioner claimed to be the owner and occupant of the two parcels of land, which respondent claimed to be part of her property. Petitioner argued that the property was still under the administration of the DENR and had not yet been declared alienable and disposable. The three other defendants in the case also asserted that respondent had no cause of action against them as she failed to establish prior physical possession of the parcels of land and did not prove that said parcels were within her property.

The Court of Appeals dismissed petitioner's Petition for Review, affirming the decision of the Regional Trial Court ordering petitioner to vacate the portions of the property he occupied.

The respondent filed a Complaint for Forcible Entry against a defendant who claimed to be the lawful possessor and occupant of two parcels of land. The defendant argued that he had been in peaceful and adverse possession of the said parcels of land for 15 years. Before the Municipal Trial Court could render a judgment, the Department of Environment and Natural Resources (DENR) issued a resolution stating that the transfer of rights in favor of the defendant was invalid and that the respondent's claim over the disputed land was valid. The DENR ordered the cancellation of the transfer of rights and directed the respondent to file a homestead application. The DENR rejected and cancelled the respondent's homestead application, leading the respondent to file a Free Patent Application. The Municipal Trial Court dismissed the respondent's Complaint for Forcible Entry for failure to prove prior physical possession of the parcels of land. The respondent appealed the decision to the Regional Trial Court.

The case involves a dispute over the ownership and possession of a 143,417-square meter property. The Regional Trial Court (RTC) favored the respondent and ordered the petitioner and his co-defendants to vacate the portions of the property that they were occupying. The RTC heavily relied on a DENR Region IV Resolution in favor of the respondent. The petitioner filed a Petition for Review before the Court of Appeals, which dismissed the petition and affirmed the RTC decision. The petitioner raised issues questioning the sufficiency of evidence to establish the respondent's ownership and possession over the property and asserting that he had prior and legal right to possession and ownership.

ISSUES:

  1. Whether or not the Court of Appeals committed an error in sustaining the claim of the respondent's exclusive ownership and possession over the property.

  2. Whether or not the Court of Appeals committed an error in holding that the property is no longer considered public land and that possession and ownership were with the respondent.

  3. Whether or not the Court of Appeals committed an error in holding that the respondent validly acquired her title over the property from the previous homestead grantee despite the petitioner's prior possession and ownership claim.

  4. Whether or not the Court of Appeals committed an error in not holding that the rejection of the respondent's homestead application permanently bars her from filing another application for free patent over the entire property.

  5. Whether or not the Court of Appeals violated the rules by allowing the introduction of titles and patents for the first time on appeal.

  6. Whether the respondent was able to establish her prior physical possession and deprivation of possession by the petitioner through force, intimidation, threat, strategy, and stealth.

  7. Whether the documents presented by the respondent, such as the DENR Resolution and the Transfer of Rights, were sufficient to prove her prior physical possession of the disputed property.

  8. Whether the evidence presented by the respondent sufficiently proves her prior possession of the disputed property.

  9. Whether the subsequent issuance of free patents and titles in favor of the respondent and her assignee affects the validity of the petitioner's free patents and titles.

  10. Whether the Court of Appeals erred in affirming the decision of the Regional Trial Court that ordered the demolition and removal of respondent's improvements on the disputed property.

RULING:

  1. n an action for forcible entry, the only issue involved is possession de facto, not possession de jure or right of possession or ownership. The main thing to be proven is prior possession and that it was lost through force, intimidation, threat, strategy, and stealth. The character of the property, whether it is still public land or not, is irrelevant in resolving the issue of possession. The Court declared that ejectment proceedings are summary proceedings intended to determine who is entitled to physical or material possession of the premises. Hence, title is not involved and even government-owned land can be subject to forcible entry cases.

  2. The Supreme Court found that the respondent was not able to satisfactorily prove her prior physical possession of the disputed property nor her being deprived of possession by the petitioner through force, intimidation, threat, strategy, and stealth. It was emphasized that the absence of prior physical possession alone already warrants the dismissal of a forcible entry complaint. The documents presented by the respondent, including the DENR Resolution and the Transfer of Rights, were deemed insufficient to establish her prior physical possession of the disputed property.

  3. The evidence presented by the respondent, such as the contract of sale, tax declaration, and real property tax clearance, does not sufficiently prove her prior possession of the disputed property. On the other hand, the petitioner submitted free patents and titles in his favor over the parcels of land he had been occupying. The court inferred from the grant of free patents to the petitioner that he had complied with the requirements, including the 30-year possession of the property subject of the patents. Therefore, the petitioner has been in possession of the two parcels of land before the respondent acquired the property.

  4. The subsequent issuance of free patents and titles in favor of the respondent and her assignee does not affect the validity of the petitioner's free patents and titles. The court upholds the validity of the petitioner's free patents and titles as they were issued earlier. Once a patent is registered and the corresponding certificate of title is issued, the land ceases to be part of the public domain and becomes private property. The court cannot extend the presumption of regularity to the respondent's free patents and titles, considering that they were preceded by the petitioner's free patents and titles.

  5. The Supreme Court reversed and set aside the decision of the Court of Appeals and reinstated the decision of the Municipal Trial Court in Cities. The Court ordered that the respondent's complaint for forcible entry be dismissed.

PRINCIPLES:

  • In ejectment suits, the issue involved is possession de facto, not possession de jure or right of possession or ownership. Title is not involved.

  • Ejectment proceedings are summary proceedings intended to provide an expeditious means of protecting actual possession or right to possession of property.

  • The character of the property, whether it is still public land or not, is irrelevant in resolving the issue of possession in forcible entry cases.

  • The main thing to be proven in an action for forcible entry is prior possession and that it was lost through force, intimidation, threat, strategy, and stealth.

  • Even government-owned land can be subject to forcible entry cases.

  • The court may litigate the issue of possession between the plaintiff and the defendant, even if the land in dispute belongs to the government and neither party is authorized to occupy it.

  • In a forcible entry case, the party with the burden of proof must establish the case by a preponderance of evidence. Mere allegations or claims are not enough.

  • In an action for forcible entry, it does not matter whether the land is public or private. What is essential is the plaintiff's prior physical possession and being unlawfully deprived thereof by force, intimidation, threat, strategy, and stealth.

  • The determination of prior physical possession and unlawful deprivation of possession is a question of fact and the factual findings of lower courts are generally binding. However, the Supreme Court may rule on factual issues as an exception to the general rule when the factual findings of the lower courts are contrary to one another.

  • In an action for forcible entry, the judgment rendered only affects possession and does not bind the title or affect ownership of the land or building.

  • The party in peaceable and quiet possession shall not be thrown out by a strong hand, violence, or terror. Courts will uphold respect for prior possession, regardless of the actual condition of the title to the property.

There are no specific legal principles or doctrines mentioned in the provided text.