Title: NATIONAL POWER CORPORATION v.

CASTILLO
Citation: G.R. No. 196140, 27 January 2016

Facts:
The NPC entered a piece of land owned by a private individual and constructed power
lines without properly initiating expropriation proceedings. Castillo filed a case to claim just
compensation and argued that the compensation must factor in the inflation from the time the
property was taken up to the time compensation was paid.

Issue/s:
1.) Whether just compensation must include the inflation rate
2.) Whether the government’s act in illegally occupying the property before instituting
expropriation proceedings is a basis for damages.

Decision of the Court:

No, if property is taken for public use before compensation is deposited with the court
having jurisdiction over the case, the final compensation must include interests on its just
value to be computed from the time the property is taken to the time when compensation is
actually paid or deposited with the court. The valuation of the land for purposes of
determining just compensation should not include the inflation rate of the Philippine Peso
because the delay in payment of the price of expropriated land is sufficiently recompensed
through payment of interest on the market value of the land as of the time of taking from the
landowner.

Yes, additional compensation in the form of exemplary damages and attorney's fees
should likewise be awarded as a consequence of the government agency's illegal occupation
of the owner's property for a very long time, resulting in pecuniary loss to the owner.

Title: GO v. LOOYUKO
Citation: G.R. No. 196529, 01 July 2013

Facts:
Looyuko filed an unlawful detainer case against Go ordering him to vacate a
townhouse. Go argued that Looyuko’s petition is improper because he failed to prove
ownership over the townhouse. Looyuko presented his TCT to prove ownership over the
townhouse while Go relied on the adverse title of his brother stating that the townhouse was
bought using partnership funds. The lower courts ruled that possession of the townhouse
belongs to Looyuko without ruling on the issue of rightful ownership.

Issue/s:
Whether possession of the townhouse may be resolved without deciding its ownership

Decision of the Court:

Yes, a person who has a Torrens Title over a land is entitled to its possession.
Resolving the question of ownership is relevant only when the question of possession cannot
be decided without resolving the issue of ownership. In this case Looyuko has a TCT which
cannot be collaterally attacked via unlawful detainer case and is sufficient evidence to entitle
him the right to possession of the townhouse. Prior physical possession is not required.

Title: NENITA QUALITY FOODS v. GALABO

Citation: G.R. No. 174191, 30 January 2013

Facts:
Galabo occupied and cultivated Lot 102 on the mistaken belief that it was part of the
land he purchased. Lot 102 was subsequently sold by the owner to Nenita (NQF) pursuant to a
Deed of Absolute Sale. NQF enlisted the help of armed policemen to dispossess Galabo.
Galabo filed a case for forcible entry. NQF argued that it had rightful ownership of the land
and is justified in evicting Galabo.

Issue/s:
Whether the NQF’s title and ownership over the land negates a forcible entry case
against it.

Decision of the Court:

No, this was a forcible entry case where the possession in issue is not exactly the same
as the possession contemplated by the concept of ownership. The possession in forcible entry
refers to physical possession/possession de facto. The party who can prove prior possession
can recover such possession even against the owner himself. Notwithstanding the character of
his possession, as long as he has prior possession in time, he has the security that entitles him
to remain on the property until a person with a better right lawfully ejects him. In this case,
NQF’s tax declaration are not conclusive proof of possession. Neither the principle of tacking
of possession, (e.g. when it bought the land from the owner, its possession is by operation of
law tacked to the owner and predecessor owners), applies because possession in this regard
pertains to possession de jure and tacking is made to complete the time required for acquiring
or losing ownership through prescription. Physical Possession of the land should remain with
Galabo without prejudice to an appropriate action for recovery of possession based on
ownership in favor of NQF

Title: URIETA v. ALFARO

Citation: G.R. No. 164402, 5 July 2010

Facts:
Urieta with other heirs sought to recover the possession of the southern portion of the
property being occupied by Alfaro. Urieta instituted and accion publiciana and argued that
they are the registered owners of the lot pursuant to a Torrens title. Alfaro on the other hand
argues that the accion publiciana has already prescribed and they own the land pursuant to a
unregistered notarized “Kasulatan ng Bilihan” wherein the mother of Urieta sold the lot to
Alfaro’s mother.

Issue/s:
Whether Urieta is entitled to recover possession of the lot from Alfaro?
Decision of the Court:
Yes, it is settled that a Torrens title is evidence of indefeasible title to property in favor
of the person in whose name the title appears. It is conclusive evidence with respect to the
ownership of the land described therein. It is also settled that the titleholder is entitled to all
the attributes of ownership of the property, including possession. Urieta is the holder of a
Torrens title over the entire lot. Alfaro relies solely on the notarized but unregistered
Kasulatan sa Bilihan to support their claim of ownership. Thus, even if respondents’ proof of
ownership has in its favor a juris tantum presumption of authenticity and due execution, the
same cannot prevail over petitioner’s Torrens title.1

Title: SUPAPO v. DE JESUS

Citation: G.R. No. 198356, 20 April 2015

Facts:
The Spouses Supapo filed an accion publiciana and compel De Jesus et.al. to vacate a
piece of land. The land registered and a TCT was issued in the name of the Spouses Supapo.
Conciliation at the barangay failed and a certificate to file action was issued in 1992 but the
Spouses commenced the accion publiciana only in 2008. De Jesus et. al. argued that the
spouses’ action has prescribed because the case was instituted only after 10 years from
issuance of the certificate to file action.

Issue/s:
Whether the spouses’ cause of action has prescribed

Decision of the Court:

No, De Jesus et. al. admit that the land was registered under the Torrens system in
favor of Spouses Supapo. Lands covered by a title cannot be acquired by prescription or
adverse possession. The person who holds a Torrens Title over a land is also entitled to the
possession thereof. The right to possess and occupy the land is an attribute and a logical
consequence of ownership. Corollary to this, is the imprescriptible right of the holder of a
Torrens Title to eject any person illegally occupying their property.

1
Note on accion publiciana: It is to recover possession only, not ownership. Still, where the parties raise the
issue of ownership, the courts may pass upon the issue to determine who between the parties has the right to
possess the property. The adjudication is not a final and binding determination of the issue of ownership; it is
only for the purpose of resolving the issue of possession, where the issue of ownership is inseparably linked to
the issue of possession. The adjudication of the issue of ownership is provisional and cannot bar an action
between the same parties involving title to the property.