G.R. No. 139539 ; February 5, 2002
CEROFERR REALTY CORPORATION, petitioner, vs. COURT OF APPEALS and ERNESTO D. SANTIAGO, respondents.

FACTS

Petitioner Ceroferr Realty Corporation filed a complaint for damages and injunction with the Regional Trial Court (RTC) against respondent Ernesto D. Santiago. Ceroferr alleged that Santiago was unlawfully claiming possession and using a vacant lot as a jeepney terminal, which Ceroferr claimed was part of its property, Lot No. 68 of the Tala Estate Subdivision, covered by its Transfer Certificate of Title (TCT). In his answer, Santiago asserted that the disputed lot was within his own property, Lot No. 90, covered by a separate TCT, and that he had a legal right to fence and use it. The conflicting claims necessitated verification and relocation surveys to determine the exact identity and location of the vacant lot.
The trial court dismissed the complaint for lack of cause of action and lack of jurisdiction. It ruled that adjudicating the claims for damages and injunction would require a determination of the validity of the parties’ respective titles and the identity of the land, which constituted a collateral attack on Santiago’s Torrens title. The Court of Appeals affirmed this dismissal, prompting Ceroferr to elevate the case to the Supreme Court via certiorari.

ISSUE

The primary issue is whether the trial court has jurisdiction to determine the identity and location of the disputed vacant lot in an action for damages and injunction, or whether doing so would constitute an impermissible collateral attack on a Torrens certificate of title.

RULING

The Supreme Court granted the petition and reversed the decisions of the lower courts. The Court held that the complaint sufficiently stated a cause of action, as it contained the three indispensable elements: a right in favor of Ceroferr, an obligation on Santiago’s part not to violate that right, and an act by Santiago allegedly constituting a violation. The Court further ruled that the trial court had jurisdiction to resolve the boundary dispute.
The legal logic is that the action did not constitute a collateral attack on Santiago’s title. A collateral attack occurs when, in another action to obtain a different relief, an attack is made on the judgment or decree awarding the title. Here, Ceroferr’s action was for damages and injunction based on its own alleged ownership and possession. The need to determine the precise location of the boundary between Lot No. 68 and Lot No. 90 to resolve the factual issue of trespass does not amount to challenging the validity or issuance of Santiago’s certificate of title itself. After original registration, jurisdiction over boundary disputes shifts from the land registration court to ordinary courts of general jurisdiction. Therefore, the RTC, in the exercise of its general jurisdiction, was competent to hear evidence, including survey reports, to ascertain the identity and location of the contested lot for the purpose of resolving the main action for damages and injunction. The case was remanded to the RTC for further proceedings.