CASE DIGEST : QUITALIG VS QUITALIG GR 207985 GAERLAN

 

SECOND DIVISION

[ G.R. No. 207958. August 04, 2021 ]

MIGUELA QUITALIG, PETITIONER, VS. ELADIO QUITALIG, RESPONDENT.

D E C I S I O N

FACTS : The case arose from a complaint for recovery of possession, damages, and injunction filed by Miguela Quitalig before the MTCC of Tarlac City, claiming ownership and possession of a 19,798-square-meter portion of Lot 5358 which she acquired from Paz G. Mendoza on March 19, 2001, and which she and her predecessor allegedly possessed, cultivated, and harvested as owners for over 30 years. She alleged that in May 2004, Eladio Quitalig forcibly entered the land with armed men, fenced and cultivated it, took the crops, and ousted her despite repeated demands to vacate. Eladio denied these claims, asserting that the land was never possessed by Miguela and that he had been in actual possession as an installed tenant of the owner Bonifacio dela Cruz, supported by lease rental receipts. The MTCC ruled for Miguela, ordering Eladio to vacate and pay attorney’s fees, and the RTC affirmed on appeal, finding Miguela’s ownership sufficiently proven and Eladio’s possession unjustified. On petition for review, the CA, while ruling that no tenancy relationship existed to vest jurisdiction in the DARAB, nevertheless reversed the MTCC and RTC, holding that Miguela failed to substantiate her allegations and that Eladio’s evidence was more credible; Miguela’s motion for reconsideration was denied, leading to the present Rule 45 petition.

ISSUE : WON The CA erred in reversing the decisions of the MTCC and RTC

HELD : The Supreme Court held the petition meritorious and ruled that the Court of Appeals (CA) gravely erred in reversing the MTCC and RTC, both procedurally and substantively. Procedurally, Eladio’s petition for review before the CA was defective for non-compliance with Sections 1–3, Rule 42 of the Rules of Court, as it was initially filed without verification, certification against forum shopping, and certified true copies of the assailed decisions, and Eladio failed to allege or prove any special circumstance justifying relaxation of the rules, making dismissal mandatory. Substantively, Eladio’s defense—that he was a tenant of Bonifacio dela Cruz and that the land was not part of Miguela’s property—was unsupported by evidence; tenancy between Miguela and Eladio never existed, divesting DARAB of jurisdiction, and Eladio himself admitted that Miguela’s property was covered by a Torrens title, which constitutes conclusive proof of ownership and carries with it the right to possession. The tax declaration relied upon by Eladio and accepted by the CA merely indicated a claim of ownership and could not prevail over Miguela’s Torrens title. The CA further erred in ruling on an unassigned issue and in finding Miguela’s evidence insufficient despite her registered title. Accordingly, the Supreme Court reversed and set aside the CA decision and resolution, and reinstated the MTCC and RTC decisions ordering Eladio to vacate the property.