Case Title Subject and Doctrine

GR No. Topic
Date

REPUBLIC v. CAPITAL LTD; Section 121 of the Public Land Act pertains to acquisitions of public land b
RESOURCES Registration corporation from a grantee. In this case, the original grantee was Dumuk and
CORPORATION through subsequently transferred the subject property to spouses Milo. In turn, the spo
G.R. No. 217210. Administrative were the ones who sold the subject property to Capital Resources and Ro
November 7, 2016, First Proceedings Roxas. Evidently, Capital Resources did not acquire the subject property from
Division (Caguioa, J.) (C.A. 141, as original grantee.
amended)
As to the provision of the 1973 Constitution proscribing corporations from
acquiring "alienable lands" of the public domain, the consistent ruling of
Supreme Court is that the prohibition will not apply if the property acquired by
corporation is private property and not alienable lands of the public domain.
rule is that once a patent is registered and the corresponding certificate of tit
issued, the land covered by it ceases to be part of the public domain and beco
private property.

HEIRS OF TOMAKIN LTD; Review of The Court stated that the sole remedy of the land owner whose property has b
v. HERIS OF decree of wrongfully or erroneously registered in another's name is, after one year from
NAVARES registration date of the decree, not to set aside the decree, but, respecting the decree
G.R. No. 223624, July incontrovertible and no longer open to review, to bring an ordinary action in
17, 2019, Second ordinary court of justice for reconveyance or, if the property has passed into
Division (Caguioa, J.) hands of an innocent purchaser for value, for damages.

AMA LAND, INC., vs. PROPERTY; Article 656 requires proof of indispensability and receipt of payment of the pr
WACK WACK RIGHT OF WAY indemnity for the damage caused by the owner of the dominant estate before
RESIDENTS' owner of the servient estate can be compelled to grant a temporary easemen
ASSOCIATION, INC. right of way.
G.R. No. 202342. July Articles 649 and 650 of the Civil Code, requisites; (1) the dominant estat
19, 2017, First Division surrounded by other immovables; (2) it is without adequate outlet to a pu
(Caguioa, J.) highway; (3) after the proper indemnity has been paid; (4) the isolation was not
to the proprietor of the dominant estate's own acts; and (5) the right of way clai
is at a point least prejudicial to the servient estate. (6) right of way mus
absolutely necessary for the normal enjoyment of the dominant estate by its own

G. HOLDINGS, INC vs. Contract; article Under Article 1345 of the Civil Code, simulation of a contract may be abso
CEPALCO 1345 when the parties do not intend to be bound at all, or relative, when the pa
G.R. No. 226213. conceal their true agreement. The characteristic of simulation is the fact that
September 27, 2017, apparent contract is not really desired or intended to produce legal effects or in
Second Division way alter the juridical situation of the parties. Thus, where a person, in orde
(Caguioa, J.) place his property beyond the reach of his creditors, simulates a transfer of
another, he does not really intend to divest himself of his title and control of
property; hence, the deed of transfer is but a sham or a simulated contract.

As to the presence of badges of fraud, which the RTC-CDO found to have exi
and affirmed by the CA, they do, in fact, confirm the intention of FPI to def
CEPALCO. But these findings do not thereby render as rescissible the Dee
Assignment under Article 1381 (3). Rather, they fortify the finding that the Dee
Assignment was "not really desired or intended to produce legal effects or in
way alter the juridical situation of the parties” or, put differently, that the Dee
Assignment was a sham, or a contracto simulado.

Rescission and nullity can be distinguished in the following manner: (a) by rea
of the basis — rescission is based on prejudice, while nullity is based on a vic
defect of one of the essential elements of a contract; (2) by reason of purpose
rescission is a reparation of damages, while nullity is a sanction; (3) by reaso
 effects — rescission affects private interest while nullity affects public interest
by reason of nature of action — rescission is subsidiary while nullity is a princ
action; (5) by reason of the party who can bring action — rescission can be brou
by a third person while nullity can only be brought by a party; and (6) by reaso
susceptibility to ratification — rescissible contracts need not be ratified
while void contracts cannot be ratified.

PRIVATIZATION AND LTD; RTC Section 107 contemplates ONLY two situations when a petition for surrende
MANAGEMENT JURISDICTION withheld duplicate certificate of title may be availed of. These are: (1) where
OFFICE vs. EDGARDO necessary to issue a new certificate of title pursuant to any involuntary instrum
V. QUESADA, et. al. which divests the title of the registered owner against his consent, and (2) whe
G.R. No. 224507, voluntary instrument cannot be
September 20, 2017, registered by reason of the refusal or failure of the holder to surrender the own
Second Division duplicate certificate of title.
(Caguioa, J.)
Further, Section 2 of P.D. No. 1529 has eliminated the distinction between
general jurisdiction vested in the regional trial court and the limited jurisdic
conferred upon it by the former law when acting merely as a cadastral court. U
the former law (Act No. 496 or the Land Registration Act), all summary re
such as the instant action to compel surrender of owner's duplicate of Title c
only be filed with the RTC sitting as a land registration court only if there
unanimity among the parties or there was no adverse claim or serious objection
the part of any party in interest. Otherwise, if the case became contentious
controversial, it should be threshed out in an ordinary action or in the case w
the incident properly belonged. Under the amended law, the court is
authorized to hear and decide not only such non-controversial cases but even
contentious and substantial issues.

REPUBLIC OF THE LTD; PUBLIC The classification and reclassification of public lands into alienable or disposa
PHILIPPINES, vs. THE LAND ACT mineral or forest land is the exclusive prerogative of the Executive Department,
HEIRS OF is exercised by the latter through the President.
MEYNARDO
CABRERA Further, owing to the nature of reversion proceedings and the outcome whic
G.R. No. 218418. favorable decision therein entails, the State bears the burden to prove that the
November 8, 2017, previously decreed or adjudicated in favor of the defendant constitutes land w
Second Division cannot be owned by private individuals.
(Caguioa, J.)
The Complaint should be dismissed as the Republic failed to show that the Ro
Properties (including Lot 1-A) were classified as forest land at the time Free Pa
No. 516197 was issued in Meynardo's favor.
COCA-COLA DAMAGES; The cases when moral damages may be awarded are specific. Unless the case
BOTTLERS PHILS., ARTICLE 2219- under the enumeration as provided in Article 2219, which is exclusive, and Ar
INC., vs. ERNANI 2220 2220 of the Civil Code, moral damages may not be awarded. Article 2
GUINGONA MEÑEZ provides: ART. 2219. Moral damages may be recovered in the following
G.R. No. 209906. analogous cases; (2) Quasi-delicts causing physical injuries; Unfortuna
November 22, 2017, Meñez has not presented evidence to prove that he suffered physical injuries w
Second Division he allegedly ingested kerosene from the "Sprite" bottle in question.
(Caguioa, J.)
As to exemplary or corrective damages, these may be granted in quasi-delicts if
defendant acted with gross negligence pursuant to Article 2231 of the Civil C
Meñez has failed to establish that CCBPI acted with gross negligence. Other
the opened "Sprite" bottle containing pure kerosene allegedly served to him a
Rosante, Meñez has not presented any evidence that would show CCB
purported gross negligence.

ARACELI MAYUGA, LTD; An action for reconveyance involving land that is titled pursuant to a free pate
vs. ANTONIO SUCCESSION one that seeks to transfer property, wrongfully registered by another, to its righ
ATIENZA and legal owner or to one with a better title. As such, two facts must be allege
G.R. No. 208197. the complaint and proved during the trial, namely: (1) the plaintiff was the owne
January 10, 2018, Second the land or possessed it in the concept of owner, and (2) the defendant illeg
Division (Caguioa, J.) divested him of ownership and dispossessed him of the land.

Article 1080 of the Civil Code, "should a person make a partition of his estate b
act inter vivos, or by will, such partition shall be respected, insofar as it does
prejudice the legitime of the compulsory heirs."
Since the Civil Code allows partition inter vivos, it is incumbent upon
compulsory heir questioning its validity to show that his legitime is impai
Unfortunately, Araceli has not shown to what extent the Confirmation Affid
prejudiced her legitime.

Araceli could not also claim preterition by virtue of the Confirmation Affidavi
the assumption that the disputed two lots pertained to Perfecto's inheritance, he
only three legal heirs and he left Araceli with no share in the two lots. Altho
Araceli was a compulsory heir in the direct descending line, she could not h
been preterited. Firstly, Perfecto left no will. As contemplated in Article 854,
presence of a will is necessary. Secondly, before his death, Perfecto had prope
in Limon, Rizal which was almost 50 hectares, part of which was developed
residential and
agricultural purposes, and in Odiongan. Araceli could not have been to
excluded in the inheritance of Perfecto even if she was not allegedly given
share in the disputed two lots. If Araceli's share in the inheritance of Perfect
claimed by her was indeed impaired, she could have instituted an action
partition or a settlement of estate proceedings instead of her complaint
cancellation of free patent and reconveyance.

REPUBLIC OF THE LTD; Testimonial evidence on the physical layout or condition of the subject land —
PHILIPPINES vs. ALIENABLE it was planted with coconut trees and beach houses had been constructed thereo
FILEMON SAROMO AND are not conclusive on the classification of the subject land as alienable agricult
G.R. No. 189803. March DISPOSABLE land. Rather, it is the official proclamation releasing the land classified as pu
14, 2018, Second LAND forest land to form part of disposable agricultural lands of the public domain th
Division (Caguioa, J.) definitive. Such official proclamation, if there is any, is conspicuously missin
the instant case.
Without the official declaration that the subject land is alienable and disposabl
proof of its declassification into disposable agricultural land, the "unclassi
public forest land's" legal classification of the subject land remains.
REPUBLIC OF THE LTD; PD 1529 The phrase "adverse, continuous, open, public, and in concept of owner,"
PHILIPPINES vs. SEC 14 conclusion of law. Burden of proof is on the person seeking original registratio
NORTHERN CEMENT land to prove by clear, positive and convincing evidence that his possession
CORPORATION that of his predecessors-in-interest was of the nature and duration required by
G.R. No. 200256, April Tax Declarations are not conclusive evidence of ownership but only a basis
11, 2018, Second inferring possession. It is only when these tax declarations are coupled with p
Division (Caguioa, J.) of actual possession of the property that they may become the basis of a claim
ownership.

In a plethora of cases, the Court has disallowed registration of lands wh

although plants and fruit-bearing trees existed on the contested lands, it was
proven that they were cultivated by the registrant, or that they were actively
regularly cultivated and maintained and not merely casually or occasionally ten
to by the registrant, or that they were planted by him or his predecessors-in-inte
Cogon grass and unirrigated rice further cements the character of the land as idl
ASTRID A. VAN DE Article 19 In order to be liable for damages under the abuse of rights principle, the follow
BRUG vs. PHILIPPINE requisites must concur: (a) the existence of a legal right or duty; (b) whic
NATIONAL BANK exercised in bad faith; and (c) for the sole intent of prejudicing or injuring anoth
G.R. No. 207004, June 6,
2018, Second Division In this case, the Aguilars failed to substantiate the above requisites to justify
(Caguioa, J.) award of damages in their favor against PNB, who merely exercised its legal r
 as a creditor pursuant to RA 7202.
D.M. RAGASA OBLIGATION; Article 1170 of the Civil Code mandates that those who, in the performance of t
ENTERPRISES, INC. ARTICLE 1170, obligations, are guilty of fraud, negligence, or delay, and those who, in any man
vs. BANCO DE ORO, 1227, 2203 contravene the tenor thereof, are liable for damages. Thus, having contrave
INC. the tenor of the Lease Contract regarding its term or period, the bank should
G.R. No. 190512, June liable for damages. However, how much in damages should the bank be lia
20, 2018, Second Generally, if the lessor or the lessee should not comply with their obligations,
Division (Caguioa, J.) aggrieved party may ask for either the rescission of the contract
indemnification for damages, or only the latter, allowing the contract to remai
force.
A penal clause is an accessory obligation which the parties attach to a princ
obligation for the purpose of insuring the performance thereof by imposing on
debtor a special prestation (generally consisting in the payment of a sum of mo
in case the obligation is not fulfilled or is irregularly or inadequately fulfi
Evidently, the penal clause may be considered either reparation, compensatio
substitute for damages, on one hand, or as a punishment in case of breach of
obligation, on the other. When considered as reparation or compensation,
question as to the appropriate amount of damages is resolved once and fo
because the stipulated indemnity represents a legitimate estimate made by
contracting parties of the damages caused by the nonfulfillment or breach of
obligation. Proof of actual damages is, consequently, not necessary in order tha
stipulated penalty may be demanded. When considered as a punishment,
question of damages is not yet resolved inasmuch as the right to damages, bes
the penalty, still subsists. Thus, if the injured party desires to recover the dam
actually suffered by him in addition to the penalty, he must prove such damages
BENEDICTO V. OBLIGATION; Novation is governed principally by Articles 1291 and 1292 of the Civil C
YUJUICO, vs. FAR 1291 which provide: ART. 1291. Obligations may be modified by: (1) Changing t
EAST BANK AND object or principal conditions; (2) Substituting the person of the debtor;
TRUST COMPANY
G.R. No. 186196. August
15, 2018, Second
Division (Caguioa, J.)
POUSES BELTRAN vs. SALE;
SPOUSES CANGAYDA OBLIGATION;
G.R. No. 225033, August 1191; 1592
15, 2018, Second
Division (Caguioa, J.)
Subrogating a third person in the rights of the creditor. Further, ART. 1
provides that in order that an obligation may be extinguished by another w
substitutes the same, it is imperative that it be so declared in unequivocal term
that the old and the new obligations be on every point incompatible with each o
The only modification that the conversion agreement introduced was that
obligation would be payable in US dollars instead of Philippine pesos. Incident
the applicable interest rate is lower on account of the change in currency. T
alterations, however, do not suffice to constitute novation.
In a contract of sale, title passes to the vendee upon the delivery of the thing s
whereas in a contract to sell, by agreement the ownership is reserved in the ven
and is not to pass until the full payment of the price. In a contract of sale,
vendor has lost and cannot recover ownership until and unless the contrac
resolved or rescinded; whereas in a contract to sell, title is retained by the ven
until the full payment of the price.
Ownership of the disputed property passed to petitioners when its possession
transferred in their favor, as no reservation to the contrary had been made. —
reason being that it is not evident from said testimony
and clause 6 that there was an express agreement to reserve ownership des
delivery of the disputed property.
It bears emphasizing that a formal document is not necessary for the
transaction to acquire binding effect. Hence, the subsequent execution of a for
deed of sale does not negate the perfection of the parties' oral contract of sale w
had already taken place upon the meeting of the parties' minds as to the subjec
the transaction and its purchase price.
Despite the denomination of the deed as a "Deed of Conditional Sale" a readin
 the conditions therein set forth reveals the contrary. Nowhere in the said contrac
question could we find a proviso or stipulation to the effect that title to the prop
sold is reserved in the vendor until full payment of the purchase price.

Article 1592 in conjunction with Article 1191 suggests that in the absence of
Stipulation to the contrary, the vendor's failure to pay within the period agreed u
shall not constitute a breach of faith, so long as payment is made before the ven
demands for rescission, either judicially, or by notarial act. In the case at
petitioner Taguba never notified private respondent by notarial act that he
rescinding the contract, and neither had he filed a suit in court to rescind the sale

Where time is not of the essence of the agreement, a slight delay on the part of
party in the performance of his obligation is not a sufficient ground for
rescission of the agreement." Considering that in the instant case, pri
respondent had already actually paid the sum of P12,500.00 of the total stipul
purchase price of P18,000.00 and had tendered payment of the balance
P5,500.00 within the grace period of six months from December 31, 1972, eq
and justice mandate that she be given additional period within which to comp
payment of the purchase price
SPOUSES ABRAHAM PROPERTY; The act of replacing the steel grille gate with a concrete fence was within
AND MELCHORA article legitimate exercise of GVHAI's proprietary rights over its property. The
ERMINO vs. GOLDEN 430;627,637 recognizes in the owner the right to enjoy and dispose of a thing, without o
VILLAGE limitations than those established by law. Article 430 of the Civil Code prov
HOMEOWNERS that "(e)very owner may enclose or fence his land or tenements by means of w
ASSOCIATION, INC. ditches, live or dead hedges, or by any other means without
G.R. No. 180808, August detriment to servitudes constituted thereon."
15, 2018, Second
Division (Caguioa, J.) Where the waters which flow from a higher state are those which are artifici
collected in man-made lagoons, any damage occasioned thereby entitles the ow

SAMUEL AND EDGAR LTD
BUYCO v. REPUBLIC
OF THE PHILIPPINES
G.R. No. 197733, August
29, 2018, Second
Division (Caguioa, J.)
INDUSTRIAL DAMAGES;
PERSONNEL AND 2199
MANAGEMENT
SERVICES, INC. v.
COUNTRY BANKERS
INSURANCE
CORPORATION
G.R. No. 194126,
October 17, 2018,
of the lower or servient estate to compensation. Lower estates are only oblige
receive water naturally flowing from higher estates and such should be free f
any human intervention. In the instant
case, what flowed from Hilltop City Subdivision was not water that natur
flowed from a higher estate. The bulldozing and flattening of the hills led to
the softening of the soil that could then be easily carried by the current of w
whenever it rained. Thus, Alco Homes and Golden Village are not anym
obligated to receive such waters and earth coming from Hilltop City Subdivision
A CENRO or PENRO certification is not enough to prove the alienable
disposable nature of the property sought to be registered because the only wa
prove the classification of the land is through the original classification appro
by the DENR Secretary or the President himself.
TWO documents that must be presented to prove that the land subject of
application for registration is alienable and disposable:
(1) a copy of the original classification approved by the DENR Secretary
certified as a true copy by the legal custodian of the official records, and
(2) a certificate of land classification status issued by the CENRO or the Provin
Environment and Natural Resources Office (PENRO) based on the
classification approved by the DENR Secretary.
According to the autonomy characteristic of contracts, the contracting parties
establish such stipulations, clauses, terms and conditions as they may d
convenient, provided they are not contrary to law, morals, good customs, pu
order, or public policy.
Article 2199 of the Civil Code states: Except as provided by law or by stipulat
one is entitled to an adequate compensation only for such pecuniary loss suff
by him as he has duly proved. Such compensation is referred to as actua
compensatory damages. The law is clear and unequivocal when it states that on
Second Division entitled to adequate compensation for pecuniary loss only for such losses as he
(Caguioa, J.) duly proved EXCEPT: (1) when the law provides otherwise, or (2) by stipulatio
the parties.
The submission of official receipts and other pieces of evidence as a prerequ
for the payment of claims is excused by stipulation of the parties; and in
thereof, the presentation of statement of accounts with detailed expenses, dem
letters, and affidavits is, by express stipulation, sufficient evidence for the paym
of claims.

Evidently, the parties did not include as preconditions for the Payment of claims
submission of official receipts or any other more direct or concrete piece
evidence to substantiate the expenditures of petitioner IPAMS. Thus, respon
Country Bankers was not justified in denying the
payment of claims presented by petitioner IPAMS based on the lack of off
receipts.
REPUBLIC OF THE LTD Accordingly, public lands not shown to have been classified, reclassified
PHILIPPINES v. SPS. released as alienable agricultural land or alienated to a private person by the S
ILDEFONSO remain part of the inalienable lands of public domain. Therefore, the onu
ALEJANDRE AND overturn, by incontrovertible evidence, the presumption that the land subject o
ZENAIDA application for registration is alienable and disposable rests with the applicant.
FERRER ALEJANDRE
G.R. No. 217336,
October 17, 2018,
Second Division
(Caguioa J.)
NARCISO LTD; PUBLIC If the land in question is proven to be of private ownership and, therefore, bey
MELENDRES, LAND ACT the jurisdiction of the Director of Lands, the free patent and subsequent title iss
SUBSTITUTED BY HIS pursuant thereto are null and void. The indefeasibility and imprescriptibly
WIFE, OFELIA Torrens title issued pursuant to a patent may be invoked only, when the
 MELENDRES AND involved originally formed part of the public domain. If it was a private land,
CHILDREN JOSE patent and certificate of title issued upon the patent are a nullity.
MARI MELENDRES,
AND NARCISO Section 44, Chapter VI of Commonwealth Act No. 141 or the Public Land
MELENDRES, JR., states that a free patent may issue in favor of an applicant only if (1) the appli
PETITIONERS, v. has continuously occupied and cultivated, either by himself or through
ALICIA CATAMBAY, predecessors-in-interest, a tract or tracts of agricultural public lands subjec
LORENZA disposition, or (2) who shall have paid the real estate tax thereon while the s
BENAVIDEZ, IN has not been occupied by any person.
SUBSTITUTION OF
HER HUSBAND The title of petitioners over the subject property is still imperfect; the issuance
EDMUNDO certificate of title in favor of petitioners is still subject to the rules on confirma
BENAVIDEZ, AND of title under Section 48 (b) of the Public Land Act. Nevertheless, as similarly
THE REGISTER OF in Heirs of Santiago v. Heirs of Santiago, this imperfect title of the petitione
DEEDS OF RIZAL enough to defeat the free patent and certificate of title issued over the sub
(MORONG BRANCH) property in favor of respondents
G.R. No. 198026, and their predecessors-in-interest.
November 28, 2018,
Second Division,
(Caguioa J.)

JUN MIRANDA v. SPS. PROPERTY;
ENGR. ERNESTO AND SALE
AIDA MALLARI AND
SPS. DOMICIANO C.
REYES AND
Accion publiciana is a plenary action to recover the better right of possession
(possession de jure), which should be brought in the proper inferior court or
Regional Trial Court (depending upon the value of the property) when the
dispossession has lasted for more than one year (or for less than a year in
cases other than those mentioned in Rule 70 of the Rules). The issue in an
CARMELITA accion publiciana is the "better right of possession" of real property
PANGAN independently of title. This "better right of possession" may or may not
G.R. No. 218343, proceed from a Torrens Title.
November 28, 2018,
Second Division
(Caguioa, J.)
VDM TRADING, INC. QUASI According to Article 2176 of the Civil Code, whoever by act or omission
AND SPOUSES LUIS DELICT causes damage to another, there being fault or negligence, is obliged to pay
AND NENA for the damage done. Such fault or negligence, if there is no pre-existing
DOMINGO, contractual relation between the parties, is called a quasi-delict. A quasi-
REPRESENTED BY delict has the following elements: a) the damage suffered by the plaintiff; b)
THEIR ATTORNEY- the act or omission of the defendant supposedly constituting fault or
IN-FACT, ATTY. F. negligence; and c) the causal connection between the act and the damage
WILLIAM L. sustained by the plaintiff, or proximate cause.
VILLAREAL v.
LEONITA In this case, none of the elements for quasi-delict are present. The
CARUNGCONG AND photographs offered into evidence by the petitioners merely depict a wet bed,
WACK WACK TWIN wet floor, and wet cabinet apparently taken from one room only, i.e., the
TOWERS master bedroom. No photographs were presented to prove that the other
CONDOMINIUM rooms of Unit 2208B-1 were also damaged by the leak.” Petitioners failed to
ASSOCIATION, INC. present even a shred of evidence that there was fault or negligence on the
G.R. No. 206709, part of the respondents Carungcong and Wack Wack
February 06, 2019,
Second Division
(Caguioa J.)
D.M. CONSUNJI, INC. LTD Mere notations appearing in survey plans are inadequate proof of the covered
v. REPUBLIC OF THE properties' alienable and disposable character. The applicant, however, must
PHILIPPINES AND also present a copy of the original classification of the land into alienable and
THE HEIRS OF disposable land, as declared by the DENR Secretary or as proclaimed by the
JULIAN President.
CRUZ, REPRESENTED
BY MACARIA CRUZ DENR Secretary had approved the land classification and released the land
ESTACIO of the public domain as alienable and disposable, and that the land
G.R. No. 233339, subject of the application for registration falls within the approved area per
February 13, 2019, verification through survey by the PENRO or CENRO. In addition, the
Second Division applicant must present a copy of the original classification of the land into
(Caguioa J.) alienable and disposable, as declared by the DENR Secretary, or as
proclaimed by the President.
HEIR OF PASTORA T. LTD As a general rule, a certificate of title serves as evidence of an indefeasible
CARDENAS AND and incontrovertible title to the property in favor of the person whose name
EUSTAQUIO appears therein. According to Section 47 of Presidential Decree No. 1529,
CARDENAS, NAMELY "no title to registered land in derogation of the title of the registered owner
REMEDIOS shall be acquired by prescription or adverse possession." There can be no
CARDENAS-TUMLOS, acquisitive prescription with respect to a titled parcel of land. The Court has
REPRESENTED BY explained that, by express provision of Section 47 of P.D. 1529, no title to
HER ATTORNEY-IN- registered land in derogation to that of the registered owner shall be acquired
FACT JANET by prescription or adverse possession.
TUMLOSQUIZON v.
THE CHRISTIAN AND right to recover possession of registered land is imprescriptible on the part of
MISSIONARY the registered owner because possession is a mere consequence of ownership.
ALLIANCE Moreover, the Court also explained that prescription is
CHURCHES OF THE unavailing, not only against the registered owner, but also against his
PHILIPPINES, INC., hereditary successors because the latter merely step into the shoes of the
REPRESENTED BY decedent by operation of law and are merely the continuation of the
REO REPOLLO AND personality of their predecessor-in-interest.
LEOCADIO DUQUE,
JR.
G.R. No. 222614, March
20, 2019, Second
Division (Caguioa J.)
ROGELIO LOGROSA LTD; It is a fundamental principle in land registration that the certificate of title
v. SPOUSES CLEOFE PROPERTY; serves as evidence of an indefeasible and incontrovertible title to the property
AND CESAR AZARES, CO- in favor of the person whose name appears therein. It becomes the best proof
SPOUSES ABUNDIO, OWNERSHIP of ownership of a parcel of land. Such principle of indefeasibility has long
JR. been well-settled in this jurisdiction and it is
AND ANTONIETA only when the acquisition of the title is attended with fraud or bad faith that
TORRES, SPOUSES the doctrine finds no application.
NELSON SALA AND
ARLENE ANG, AND A person may exercise the right to compel the partition of real estate if
SPOUSES he/she sets forth In his/her complaint the nature and extent of his title and
BONIFACIO, JR., AND subsequently proves the same. The law does not make a distinction as to how
WELHELMINA the co-owner derived his/her title, may it be through gratuity or through
BARUIZ onerous consideration. In other words, a person who derived his title and was
G.R. No. 217611, March granted co-ownership rights through gratuity may compel partition.
27, 2019, Second
Division (Caguioa J.
HUN HYUNG PARK v. LOAN In accordance with Article 1956 of the Civil Code, no interest shall be due
EUNG WON CHOI unless it has been expressly stipulated in writing. Here, without further proof
G.R. No. 220826, March of any express agreement that P375,000.00 of the P1,875,000.00 pertains to
27, 2019, Second interest, the Court is predisposed, based on the facts of the case, to rule that
Division (Caguioa J.) the entire principal amount owed by Choi to Park is the face value of the
check, or P1,875,000.00.
VIVENCIO DALIT v. LTD One of the modes by which DAR implements the distribution of agricultural
SPOUSES ROLANDO lands under the CARP is through the issuance of a CLOA. A CLOA is a
E. BALAGTAS, SR. document evidencing ownership of the land granted or awarded to the
AND CARMELITA G. qualified ARB, and contains the restrictions and conditions of such grant.
BALAGTAS, The issuance of CLOA No. T-2165 in Dalit's favor thus confirms his right to
ROLANDO G. retain possession over the portion of the Disputed Lot identified thereunder,
BALAGTAS, JR., such possession being an attribute of ownership granted in his favor. the
CLARINA G. State recognizes the
BALAGTAS, indefeasibility of CLOAs issued in accordance with applicable law. Under
CARLOTA G. DAR Administrative Order No. 07-14, the cancellation of erroneously issued
BALAGTAS, CLOAs may be allowed only in the manner and under the conditions
CARMELA G. prescribed thereunder. Until duly cancelled in accordance with the prescribed
BALAGTAS, procedure, CLOAs issued by the DAR shall remain valid and subsisting and
SOFRONIO SARIENTE enjoy the same respect accorded to those issued through other modes of
AND METROPOLITAN acquisition of title.
BANK AND TRUST
COMPANY
G.R. No. 202799, March
27, 2019, Second
Division (Caguioa J.)
KAREN NUÑEZ VITO, OBLIGATION Under Article 1245 of the Civil Code, there is dation in payment when
LYNETTE NUÑEZ S property is alienated to the creditor in satisfaction of a debt in money and is
MASINDA, WARREN governed by the law of sales.
NUÑEZ, AND To summarize, the remedies of the unpaid seller, after ownership of the real
ALDEN NUÑEZ v. property not covered by Republic Act No. 6552 or the Maceda Law, has been
NORMA MOISES- vested to the buyer, are:
PALMA 1. To compel specific performance by filing an action against the buyer for
G.R. No. 224466 the agreed purchase price; or
(Formerly UDK-15574), 2. To rescind or resolve the contract of sale either judicially or by a notarial
March 27, 2019, Second act; and
Division (Caguioa J.) 3. In either (1) or (2), to recover damages for the breach of the contract
 Article 1291 of the Civil Code, obligations may be modified by: (1)
changing their object or principal conditions; (2) substituting the person of
the debtor; and (3) subrogating a third person in the rights of the creditor.

Given the foregoing, the CA erred in its finding that the transaction between
the parties is a dation in payment or dacion en pago. The MTC and RTC
were, therefore, correct in considering the transaction as a contract of sale
DOMESTIC Extra In order to establish the application of solutio indebiti in a given situation,
PETROLEUM contractual two conditions must
RETAILER CORP. v. obligations; concur: (1) a payment is made when there exists no binding relation between
MANILA Article 2154 the payor who
INTERNATIONAL has no duty to pay, and the person who received the payment, and (2) the
AIRPORT payment is made
AUTHORITY through mistake, and not through liberality or some other cause.18 In the
G.R. No. 210641, March instant case, the
27, 2019, En Banc Court finds that the essential requisites of solutio indebiti are not present.
(Caguioa, J.
Q; Whether the refund of the increased rentals is based on solution indebiti?
A; a. There exists a binding relation between petitioner DPRC and
respondent MIAA. It is undisputed by all parties that respondent MIAA and
petitioner DPRC are mutually bound to each other under a Contract of
Lease. Hence, with respondent MIAA and petitioner DPRC having the
juridical relationship of a lessor-lessee, it cannot be said that in the instant
case, the overpayment of monthly rentals
was made when there existed no binding juridical tie or relation between the
pay or, i.e., petitioner DPRC, and the person who received the payment, i.e.,
respondent MIAA. In fact, respondent MIAA itself acknowledged in its
Comment that there was.
 For the concept of solutio indebiti to apply, the undue payment must have
been made by reason of either an essential mistake of fact or a mistake in the
construction or application of a doubtful or difficult question of law. Mistake
entails an error, misconception, or
misunderstanding. In the instant case, petitioner DPRC made the
overpayments in monthly rentals from
December 11, 1998 to December 5, 2005 not due to any mistake, error, or
omission as to any factual matter surrounding the payment of rentals.
VICTORIA T. CONTRACT; Independent and in spite of the statute of frauds, courts of equity have
FAJARDO v. BELEN TATUTE OF enforced oral partition when it has been completely or partly performed. In
CUA-MALATE FRAUD the instant case, there is no refutation on the part of petitioner Victoria as to
G.R. No. 213666, March respondent Belen's assertion that the terms of the Compromise Agreement
27, 2019, En Banc have already been partially performed by the parties.
(Caguioa, J.)
G.R. No. 194114, March PROPERTY; Raising the invalidity of a certificate of title in an action for quieting of title
27, 2019, En Banc QUIETNIG is NOT a collateral attack because it is central, imperative, and essential in
(Caguioa, J.) OF TITLE such an action that the complainant Shows the invalidity of the deed which
casts cloud on his title. In other words, at the heart of the Complaint for
Quieting of Title instituted by petitioner FEMCO is the nullification of OCT
No. 0-040 in order to remove the cloud besetting its own title. This is
manifestly a direct attack.
HIPOLITO AGUSTIN SALE While a stipulation or promise to the effect that a seller shall execute a deed
AND IMELDA of sale upon the
AGUSTIN v. ROMANA completion of payment of the purchase price by the buyer may be considered
DE VERA a factor or a sign
G.R. No. 233455, April that a contract might possibly be a contract to sell, such stipulation in itself,
03, 2019, En Banc taken in isolation,
(Caguioa, J. is by no means determinative and conclusive as to the contract being a
 contract to sell. Still
controlling are (1) the lack of any stipulation in the sale contract reserving
the title of the
property on the vendors and (2) the lack of any stipulation giving the sellers
the right to
unilaterally rescind the contract upon non-payment of the balance thereof
within a fixed
period. The absence of such stipulations in a sale contract makes the said
contract a contract
of sale. Hence, the Contract to Purchase and Sale entered into by Gregorio
and Hipolito is
a contract of sale.
SPOUSES JOHN T. SY EQUITABLE An equitable mortgage is defined as one which although lacking in some
AND LENY N. SY, MORTGAGE formality, or form or
AND VALENTINO T. words, or other requisites demanded by a statute, nevertheless reveals the
SY intention of the
v. MA. LOURDES DE parties to charge real property as security for a debt, and contains nothing
VERA-NAVARRO impossible or
AND BENJAEMY HO contrary to law. Its essential requisites are: (1) that the parties entered into a
TAN contract
LANDHOLDINGS, denominated as a contract of sale; and (2) that their intention was to secure
INC., an existing debt
HEREIN by way of a mortgage.
REPRESENTED BY
GRACE T. MOLINA,
IN HER CAPACITY AS
CORPORATE
SECRETARY
G.R. No. 239088, April
03, 2019, En Banc
(Caguioa, J.
GENEROSO SEPE v. CONTRACT Article 1354 of the Civil Code provides: "Although the cause is not stated in
HEIRS OF the contract, it is
ANASTACIA* presumed that it exists and is lawful, unless the debtor proves the contrary."
KILANG, REP. BY Otherwise stated,
HER CHILDREN the law presumes that even if the contract does not state a cause, one exists
MARIA, and is lawful; and
DONATA, it is incumbent on the party impugning the contract to prove the contrary. If
FELICIANA, the cause is stated
DOMINGA AND in the contract and it is shown to be false, then it is incumbent upon the party
SEVERO ALL enforcing the
SURNAMED SOLIJON contract to prove the legality of the cause.
G.R. No. 199766, April
10, 2019, En Banc
(Caguioa, J.
G.R. No. 213517, April LTD Tax declarations and tax receipts as evidence of ownership cannot prevail
10, 2019, En Banc over a certificate of
(Caguioa, J.) title which, to reiterate, is a presumptive proof of ownership.
PEOPLE OF THE DAMAGES Moral and exemplary damages of P500,000.00 and P100,000.00,
PHILIPPINES v. respectively, are ordinarily awarded in cases of Trafficking in Persons as a
SUSAN SAYO Y prostitute. The ratio for the award of damages
REYES AND was explained by the Court in People v. Lalli, where it ruled that “the
ALFREDO ROXAS Y criminal case of Trafficking in Persons as a Prostitute is an analogous case to
SAGON the crimes of seduction, abduction, rape, or
G.R. No. 227704, April other lascivious acts
10, 2019, En Banc
(Caguioa, J.
SPOUSES ISIDRO R. SUCCESSION Reading Article 777 of the Civil Code together with the pertinent provisions
SALITICO AND ; LTD of PD 1529 and the
CONRADA C. Rules of Court, while an heir may dispose and transfer his/her hereditary
SALITICO share to another
v. HEIRS OF person, before the transferee may compel the issuance of a new certificate of
RESURRECCION• title covering
MARTINEZ FELIX, specific property in his/her name, a final order of distribution of the estate or
NAMELY: LUCIANO, the order in
CORAZON AND anticipation of the final distribution issued by the testate or intestate court
CONCEPCION, ALL must first be had.
SURNAMED FELIX,
RECAREDO P.
HERNANDEZ, IN HIS
CAPACITY AS
ADMINISTRATOR OF
THE ESTATE OF
AMANDA H.
BURGOS, AND THE
REGISTER OF
DEEDS
G.R. No. 240199, April
10, 2019, En Banc
(Caguioa, J.