G.R. No. 146513 July 30, 2004
Lucia G. Miranda, petitioner, vs. Esperanza B. Besa, respondent.

FACTS

Macaria Capuno owned two lots in Capas, Tarlac. In 1953, she sold a 254.03-square-meter portion to Spouses Alejandro Miranda and Feliza Garcia. The spouses had the property surveyed in 1957, resulting in a technical description of 289 square meters. In 1960, Capuno filed a land registration application for her lots, which was granted without opposition from the Miranda spouses. Original Certificate of Title (OCT) No. O-1278 was issued in Capuno’s name. Capuno later sold a larger lot (Lot 18) to Atty. Tomas Besa, which was subsequently subdivided. Respondent Esperanza B. Besa, through transfers, eventually acquired a subdivided portion, Lot 18-F-3-B-2-B-1, with an area of 253 square meters. She discovered that petitioner Lucia Miranda, daughter of the original vendees, was occupying a portion of this lot.
Respondent filed an unlawful detainer complaint against petitioner in 1997, alleging ownership based on her Transfer Certificate of Title (TCT) and that petitioner was occupying the land without permission. The Municipal Circuit Trial Court (MCTC) ruled in favor of respondent, ordering petitioner to vacate. The Regional Trial Court (RTC) and the Court of Appeals affirmed the MCTC decision.

ISSUE

Whether the Court of Appeals erred in affirming the lower courts’ decisions ordering petitioner to vacate the subject property.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The core issue in an unlawful detainer case is the right to physical possession, and the sole question for resolution is who has a better right to possession. The Court held that respondent, as the registered owner under TCT No. 292806, had a superior right to possession. Registration under the Torrens system is conclusive evidence of title. Petitioner’s claim of ownership, based on the 1953 deed of sale from Capuno to her parents, could not prevail over respondent’s registered title. The Court emphasized that the action for unlawful detainer was not a bar to petitioner pursuing a separate action to assert ownership, but such claim could not be used to defeat the ejectment case where respondent’s title was established.
Furthermore, the Court found no merit in petitioner’s arguments regarding prescription and the failure to implead indispensable parties. For acquisitive prescription to apply, possession must be in the concept of an owner, which petitioner failed to prove as her possession was merely tolerated. Regarding parties, the Court ruled that petitioner’s siblings and husband were not indispensable parties to the ejectment suit, as a final determination could be made against petitioner alone concerning her specific occupancy. The failure to implead them was not fatal to the case.