Salvador v. Patricia - Alcaraz

petitioners and Ciriano Mijares from their houses which the land is
owned by City of Manila.

Full Case Title: GUILLERMO SALVADOR, REMEDIOS CASTRO, represented by
PAZ "CHIT" CASTRO, LEONILA GUEVARRA, FELIPE MARIANO, RICARDO DE  A preliminary injunction was served and granted. All parties agreed
GUZMAN, VIRGILIO JIMENEZ, represented by JOSIE JIMENEZ, ASUNCION and admitted in evidence by stipulation as to the authenticity of the
JUAMIZ, ROLANDO BATANG, CARMENCITA SAMSON, AUGUSTO TORTOSA, documents held by Patricia, Inc. And the City of Manila.
represented by FERNANDO TORTOSA, SUSANA MORANTE, LUZVIMINDA  The only issue to settle was where are the boundaries based on the
BULARAN, LUZ OROZCO, JOSE SAPICO, LEONARDO PALAD, ABEL BAKING, description in the respective titles?
represented by ABELINA BAKING, GRACIANO ARNALDO, represented by
 RTC ruled in favor of petitioners permanently enjoining respondent
LUDY ARNALDO, JUDITH HIDALGO, and IGMIDIO JUSTINIANO, CIRIACO
MIJARES, represented by FREDEZWINDA MIJARES, JENNIFER MORANTE, from evicting petitioners from their houses and collecting rental
TERESITA DIALA, and ANITA P. SALAR, petitioners, vs. PATRICIA, INC., payments from them.
respondent.  CA reversed the RTC’s decision and dismissed the complaint stating
that petitioners did not have the legal interest for quieting of title.
Doctrine: Jurisdiction cannot be presumed or implied, but must appear
clearly from the law or it will not be held to exist, but it may be conferred on
Issue/s: Whether or not the CA erred in dismissing the petitioners’ complaint?
a court or tribunal by necessary implication as well as by express terms. It
cannot be conferred by the agreement of the parties; or by the court's
acquiescence; or by the erroneous belief of the court that it had jurisdiction; Ratio/ Legal Basis: No. The Court ruled that the appeal lacks merit based on 5
or by the waiver of objections; or by the silence of the parties. aspects:
 Jurisdiction over a real action depends on the assessed value of the
Recit - Ready Summary: petitioners filed 2 causes of action of injunction and property involved as alleged in the complaint – the complaint did not
quieting of title against a property that was owned by Patricia Inc and the properly allege which court would have jurisdiction to hold their
City of Manila. The RTC ruled against and enjoined the respondent from
separate causes of action for injunction and for quieting of title. Based
evicting and collecting rent from the petitioners. The CA reversed the RTC’s
decision. Petitioner’s appealed to the SC which the court dismissed for lack on Sec. 19 of BP 129, the RTC had jurisdiction over the cause of action
of merit. The facts alleged in the complaint filed by petitioners proved that for injunction because it dealt with a subject of litigation that is
they had no right over the land they live in. The Court has mentioned that incapable of pecuniary estimation. But the RTC does not have
there have been lapses committed by petitioners and the RTC, because if exclusive jurisdiction over the cause of action of quieting of title
the complaint filed by the petitioner alleged all necessary information, the because based on the same law Sec. 33 states that first level courts
RTC may have ruled if such court has jurisdiction. (MTC, MeTC) may have jurisdiction but it would still depend on the
assessed value of the property in dispute. And because there was no
Facts: assessed value on the property alleged in the complaint, the RTC
 The case is based on an action for injunction and quieting of title to cannot simply provide a decision.
determine who owns the property occupied by the plaintiffs and  The joinder of the action for injunction and the action to quiet title –
Ciriano Mijares. And it also to prevent respondent from evicting the because the action for injuction is an ordinary suit while the quieting
of titile is a special civil action, the RTC must have severed the causes only by direct proceedings, not as an issue incidentally raised by the
of action through motion and tried them separately. parties herein.
 The petitioners did not show that they were real parties in interest
to demand either injunction or quieting of title - But "for an action to Disposition: WHEREFORE, the Court AFFIRMS the decision promulgated on
quiet title to prosper, two indispensable requisites must concur, June 25, 2010 by the Court of Appeals in CA-G.R. CV No. 86735; and ORDERS
namely: (1) the plaintiff or complainant has a legal or an equitable title the petitioners to pay the costs of suit.
to or interest in the real property subject of the action; and (2) the
deed, claim, encumbrance, or proceeding claimed to be casting cloud
on his title must be shown to be in fact invalid or inoperative despite
its prima facie appearance of validity or legal efficacy. Nowhere in the
complaint did the petitioners (plaintiffs) alleged that they had the
interest to bring the suit because they did not claim ownership on the
land and they did not show any authority which would prove the
lawfulness of their occupancy possession of the property.
 The petitioners did not have a cause of action for injunction - Two (2)
requisites must concur for injunction to issue: (1) there must be a right
to be protected and (2) the acts against which the injunction is to be
directed are violative of said right. Particularly, in actions involving
realty, preliminary injunction will lie only after the plaintiff has fully
established his title or right thereto by a proper action for the
purpose. The petitioners only raised the boundary dispute between
Patricia Inc. And the City of Manila, they did not prove that they had
an existence of a right to be protected.
 Sec. 5, Rule 10 of the Rules of Court did not save the day for the
petitioners - First of all, a boundary dispute should not be litigated in
an action for the quieting of title due to the limited scope of the
action. The action for the quieting of title is a tool specifically used to
remove of any cloud upon, doubt, or uncertainty affecting title to real
property; 45 it should not be used for any other purpose. And,
secondly, the boundary dispute would essentially seek to alter or
modify either the Torrens title of the City of Manila or that of Patricia,
Inc., but any alteration or modification either way should be initiated

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petitioners and Ciriano Mijares from their houses which the land is

owned by City of Manila.

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