Title Salvador vs. Patricia, Inc.
Case G.R. No. 195834
Decision Date Nov 9, 2016
Petitioners sought injunction and quieting of title over disputed land in Tondo, Manila, claiming City
ownership. SC affirmed CA, dismissing due to lack of jurisdiction, improper joinder, and failure to prove
legal interest. Boundary disputes require direct proceedings, not collateral attacks.
Facts:
1. Parties Involved:
Petitioners: Guillermo Salvador, Remedios Castro (represented by Paz "Chit" Castro),
Leonila Guevarra, Felipe Mariano, Ricardo de Guzman, Virgilio Jimenez (represented by
Josie Jimenez), Asuncion Juamiz, Rolando Batang, Carmencita Samson, Augusto
Tortosa (represented by Fernando Tortosa), Susana Morante, Luzviminda Bularan, Luz
Orozco, Jose Sapico, Leonardo Palad, Abel Baking (represented by Abelina Baking),
Graciano Arnaldo (represented by Ludy Arnaldo), Judith Hidalgo, and Igmidio Justiniano,
Ciriaco Mijares (represented by Fredezwinda Mijares), Jennifer Morante, Teresita Diala,
and Anita P. Salar.
Respondent: Patricia, Inc.
Intervenors-Appellees: The City of Manila and Ciriaco C. Mijares.
2. Nature of the Case:
The case involves an action for injunction and quieting of title to determine ownership
of a parcel of land occupied by the petitioners along Juan Luna Street, Gagalangin,
Tondo, Manila.
The petitioners sought to prevent Patricia, Inc. from evicting them and collecting rentals,
claiming that the land belonged to the City of Manila.
3. Key Documents:
Transfer Certificate of Title (TCT) No. 44247 in the name of the City of Manila.
TCT No. 35727 in the name of Patricia, Inc.
Approved Plan PSD-38540 and Subdivision Plan PCS-3290 for Ricardo Manotok.
4. Procedural History:
The Regional Trial Court (RTC) ruled in favor of the petitioners, permanently enjoining
Patricia, Inc. from evicting them and collecting rentals.
The Court of Appeals (CA) reversed the RTC's decision, dismissing the complaint for lack
of merit.
5. Boundary Dispute:
The RTC appointed geodetic engineers to determine the boundaries of the properties
covered by TCT No. 44247 (City of Manila) and TCT No. 35727 (Patricia, Inc.).
The majority of the commissioners concluded that the land belonged to the City of
Manila.
Issue:
1. Whether the CA erred in dismissing the petitioners' complaint for quieting of
title and injunction.
2. Whether the petitioners had the necessary legal or equitable interest to maintain the action for
quieting of title.
3. Whether the joinder of causes of action (injunction and quieting of title) was proper under the
Rules of Court.
4. Whether the boundary dispute between the City of Manila and Patricia, Inc. could be resolved in
an action for quieting of title.
5. Whether the petitioners had a valid cause of action for injunction.
Ruling:
The Supreme Court affirmed the decision of the Court of Appeals, dismissing the petitioners' complaint.
The Court held:
1. Jurisdiction:
The RTC lacked jurisdiction over the action for quieting of title because the complaint did
not allege the assessed value of the property, which is essential to determine the proper
court with jurisdiction.
2. Joinder of Causes of Action:
The joinder of the action for injunction (an ordinary suit) and quieting of title (a special
civil action) was improper under Section 5, Rule 2 of the Rules of Court.
3. Real Party in Interest:
The petitioners failed to prove they had legal or equitable title to the property. Their
possession was merely tolerated, and they did not claim ownership of the land itself.
4. Injunction:
The petitioners did not establish a right to be protected by injunction. The boundary
dispute concerned only the City of Manila and Patricia, Inc., not the petitioners.
5. Boundary Dispute:
A boundary dispute cannot be litigated in an action for quieting of title. Any alteration or
modification of a Torrens title must be done through a direct proceeding, not a collateral
attack.
Ratio:
1. Jurisdiction in Real Actions:
Jurisdiction over a real action (e.g., quieting of title) depends on the assessed value of
the property as alleged in the complaint. The absence of this allegation renders the
complaint dismissible for lack of jurisdiction.
2. Joinder of Causes of Action:
Special civil actions (like quieting of title) cannot be joined with ordinary actions (like
injunction) unless they fall under the same jurisdiction and venue.
3. Real Party in Interest:
To maintain an action for quieting of title, the plaintiff must have legal or equitable
title to the property. Mere possession, even if long-standing, does not suffice.
4. Injunction Requirements:
Injunction requires the existence of a right to be protected and a showing that the
defendant's acts violate that right. The petitioners failed to establish such a right.
5. Collateral Attack on Torrens Titles:
A Torrens title cannot be collaterally attacked in an action for quieting of title. Any
challenge to the title must be made through a direct proceeding.
