PUNONG BARANGAY DANTE PADAYAO VS. GOV. LUIS RAYMUND F. VILLAFUERTE, JR., ATTY. JANIS IAN REGASPI-CLEOFE, JOSE FRANCISCO L. MUSA, JR., LUIS ZULUETA, JOVIE VILLAREAL, DONDON OBIAS AND THE PROVINCIAL GOVERNMENT OF CAMARINES SUR, AS WELL AS EVERY OTHER INDIVIDUAL AND/OR INDIVIDUALS, WHETHER CLAIMING,…
- G.R. Number: G.R. No. 260415
- Promulgated: 2025-01-15
- Ponente: INTING, J.
Doctrine
## Facts of the Case Punong Barangay Dante Padayao (Dante) filed a complaint for recovery of possession and damages with an application for a temporary restraining order and/or writ of preliminary mandatory injunction against Governor Luis Raymund F. Villafuerte, Jr. and the Provincial Government of Camarines Sur, among others (respondents). The subject of the case is Pitogo Island, Caramoan, Camarines Sur, specifically Lot Nos. 6972 and 6973. Lot No. 6973 is covered by Katibayan ng Orihinal na Titulo Blg. 35669 (KOT Blg. 35669) in the name of the Heirs of Mario Padayao, represented by Dante. In January 2009, respondents informed Pitogo Island residents they must vacate, citing it as a protected area and danger zone. On January 20, 2009, armed men, including some respondents, told residents to leave or face demolition. On February 4, 2009, respondents, with armed men, demolished structures on the island, including Dante's. Dante and his predecessors claimed continuous possession since 1920, with real property tax payments dating back to 1945. A survey plan for both lots was issued to Dante’s predecessor, Julio Padayao, in 1934. Dante presented certifications from DENR officials indicating Pitogo Island is alienable and disposable, not a protected area, contrary to respondents' claims. The Regional Trial Court (RTC) ruled in favor of Dante, ordering respondents to vacate and restore possession of both Lot Nos. 6972 and 6973 to him, finding the island alienable and disposable and Dante having a better right of possession. The Court of Appeals (CA) affirmed the RTC's decision but modified it, stating that Dante should only be restored possession of Lot No. 6973, as he failed to prove ownership of Lot No. 6972. Dante appealed to the Supreme Court. ## Issues 1. Whether the RTC had jurisdiction over Dante's complaint, considering it was an action for forcible entry despite being labeled an *accion publiciana* and lacking an explicit statement of assessed value in the complaint. 2. Whether Dante has a better right of possession over both Lot Nos. 6972 and 6973. ## Decision / Rationale **Issue 1:** The Court held that the RTC had jurisdiction over the case. The Court noted that Dante's complaint, although labeled an *accion publiciana*, was filed within one year of dispossession (February 4, 2009 demolition to January 20, 2010 filing), making it an action for forcible entry under **Rule 70 of the Rules of Court**. The allegations in the complaint, which described dispossession by force, intimidation, and violence, also fit the description of forcible entry. Regarding the lack of an explicit statement of the assessed value in the complaint, which is crucial for determining jurisdiction in actions involving title to or possession of real property, the Court acknowledged that the complaint would ordinarily be dismissible. However, respondents actively participated in the case and sought reliefs before the RTC without raising the issue of jurisdiction. Therefore, the Court applied the doctrine of **estoppel**, precluding respondents from averring the lack of RTC jurisdiction at this stage. Evidence later presented during trial, such as the Certification from the Office of the Municipal Treasurer (PHP 18,680.00) and the Field Appraisal and Assessment Sheets (FAAS) for Lot No. 6972 (PHP 26,130.00) and Lot No. 6973 (PHP 18,680.00), indicated that the aggregate assessed value of the properties exceeded the jurisdictional threshold of PHP 20,000.00 for RTCs outside Metro Manila at the time the complaint was filed under **Batas Pambansa Blg. 129**, as amended by **Republic Act No. 7691**. **Issue 2:** The Court ruled that Dante has a better right of possession over both Lot Nos. 6972 and 6973. The Court agreed with the CA that Dante has a better right of possession over Lot No. 6973 because it is covered by **KOT Blg. 35669**, a patent title. The issuance of a patent title under **Commonwealth Act No. 141** implies prior continuous occupation…
Keywords
Rule 45 Rules of Court, Rule 70 Rules of Court, Batas Pambansa Blg. 129 Section 19, Republic Act No. 7691, Commonwealth Act No. 141 Section 101, Presidential Decree No. 1529, Republic Act No. 11573 Section 7, Republic Act No. 7586 Section 5, Republic Act No. 7586 Section 6, Proclamation No. 291, Doctrine of Estoppel, Recovery of Possession, Property Registration, Land Classification, Forcible Entry, Appeal by Certiorari, accion publiciana, jurisdiction, assessed value, alienable and disposable lands