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    SALVADOR V PATRICIA

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    VinceOnikaa PerryGermanotta
    This case involves a dispute over ownership of a property occupied by plaintiffs in Manila. The plaintiffs filed an action for injunction and quieting of title against defendant Patricia Inc. to prevent their eviction, claiming the property belongs to the City of Manila. The RTC ruled in favor of the plaintiffs, but the CA reversed, finding the plaintiffs did not have the necessary legal or equitable title to maintain a suit for quieting of title. The Supreme Court upheld the CA's ruling, stating (1) the action for injunction and quieting of title should have been severed; and (2) for an action to quiet title to succeed, the plaintiff must prove they have a legal or equitable title/interest in the property and invalidate the

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    SALVADOR V PATRICIA

    Uploaded by

    VinceOnikaa PerryGermanotta
    17 views2 pages
    This case involves a dispute over ownership of a property occupied by plaintiffs in Manila. The plaintiffs filed an action for injunction and quieting of title against defendant Patricia Inc. to prevent their eviction, claiming the property belongs to the City of Manila. The RTC ruled in favor of the plaintiffs, but the CA reversed, finding the plaintiffs did not have the necessary legal or equitable title to maintain a suit for quieting of title. The Supreme Court upheld the CA's ruling, stating (1) the action for injunction and quieting of title should have been severed; and (2) for an action to quiet title to succeed, the plaintiff must prove they have a legal or equitable title/interest in the property and invalidate the

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    SALVADOR v PATRICIA

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    This case involves a dispute over ownership of a property occupied by plaintiffs in Manila. The plaintiffs filed an action for injunction and quieting of title against defendant Patricia Inc. to prevent their eviction, claiming the property belongs to the City of Manila. The RTC ruled in favor of the plaintiffs, but the CA reversed, finding the plaintiffs did not have the necessary legal or equitable title to maintain a suit for quieting of title. The Supreme Court upheld the CA's ruling, stating (1) the action for injunction and quieting of title should have been severed; and (2) for an action to quiet title to succeed, the plaintiff must prove they have a legal or equitable title/interest in the property and invalidate the

    Copyright:

    © All Rights Reserved
    17 views2 pages

    SALVADOR V PATRICIA

    Uploaded by

    VinceOnikaa PerryGermanotta
    This case involves a dispute over ownership of a property occupied by plaintiffs in Manila. The plaintiffs filed an action for injunction and quieting of title against defendant Patricia Inc. to prevent their eviction, claiming the property belongs to the City of Manila. The RTC ruled in favor of the plaintiffs, but the CA reversed, finding the plaintiffs did not have the necessary legal or equitable title to maintain a suit for quieting of title. The Supreme Court upheld the CA's ruling, stating (1) the action for injunction and quieting of title should have been severed; and (2) for an action to quiet title to succeed, the plaintiff must prove they have a legal or equitable title/interest in the property and invalidate the

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    of 2

    SALVADOR v PATRICIA

    GR No. 195834
    November 9, 2016
    SALVADOR v PATRICIA

    GR No. 195834 November 9, 2016

    FACTS:

    This is an action for injunction and quieting of title to determine who owns the property occupied by the
    plaintiffs and intervenor, Ciriano C. Mijares. Additionally, to prevent the defendant Patricia Inc. from
    evicting the plaintiffs from their respective improvements along Juan Luna Street, plaintiffs applied for a
    preliminary injunction in their Complaint pending the quieting of title on the merits. A Complaint-in-
    Intervention was filed by the City of Manila as owner of the land occupied by the plaintiffs. A preliminary
    injunction was granted and served on all the defendants. Based on the allegations of the parties
    involved, the main issue to be resolved is whether the improvements of the plaintiffs stand on land that
    belongs to Patricia Inc., or the City of Manila. Who owns the same? Is it covered by a Certificate of Title?
    Since the Transfer Certificates of Title of both Patricia Inc. and the City of Manila are admitted as
    genuine, the question now is on the boundaries based on the description in the respective titles. On
    May 30, 2005, the RTC rendered judgment in favor of the petitioners and against Patricia, Inc.,
    permanently enjoining the latter from doing any act that would evict the former from their respective
    premises, and from collecting any rentals from them.

    On appeal, the CA reversed the RTC's judgment, and dismissed the complaint. The CA declared that the
    petitioners were without the necessary interest, either legal or equitable title, to maintain a suit for
    quieting of title; castigated the RTC for acting like a mere rubber stamp of the majority of the
    commissioners; opined that the RTC should have conducted hearings on the reports of the
    commissioners; ruled as highly improper the adjudication of the boundary dispute in an action for
    quieting of title.

    ISSUE:

    Whether the petitioners may file an action quieting of title?

    RULING:

    NO. The joinder of the action for injunction and the action to quiet title was disallowed
    By the Rules of Court (Sec. 5 (b), Rule 63 – The joinder shall not include special civil actions or
    actions governed by special rules). Thus, RTC should have severed the causes of action either
    upon motion or motu propio, and tried them separately, assuming it had Jurisdiction based
    on Section 6, Rule 2 of the Rules of Court (Misjoinder of causes of action - not a ground
    for dismissal of an action).
    "The petitioners failed to allege and prove their interest to maintain the suit. Hence, the
    dismissal of this cause of action was warranted. An action for quieting of title is essentially a
    common law remedy grounded on equity...But "for an action to quiet title to prosper, two
    indispensable requisites must concur, namely: (1) the plaintiff or complainant has a legal or an
    equitable title 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.
    The petitioners did not claim ownership of the land itself, and did not show their
    authority or other legal basis on which they had anchored their alleged lawful occupation and
    superior possession of the property. "

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