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MIRANDA v. ERNESTO
MIRANDA v. ERNESTO
FACTS:
The Spouses Mallari filed the suit [for recovery of possession] below against
Jun Miranda (Miranda). Thereunder, they alleged that, sometime after causing the
Certificate of Sale in their favor to be annotated in TCT No. NT-266485, they
conducted an inspection of the subject property. At which time, they discovered
that the same was in the possession of Miranda who claimed to be the owner
thereof, having bought the property from the Spouses Reyes sometime in 1996.
Claiming to be entitled to the ownership and possession of the property, they
prayed that Miranda be ordered to vacate and to surrender the possession thereof to
them. Miranda denied all the material allegations in the Spouses Mallari's
complaint. He averred that he is already, and continues to be, the owner of the
subject property as he bought the same from the Spouses Reyes. Claiming to be an
innocent purchaser for value who cannot be deprived of possession over the
subject property, he prayed that the complaint be dismissed, that he be declared the
rightful owner of the subject property, and for an award of damages.
The RTC rendered judgment in favor of the plaintiffs-spouses Ernesto and
Aida Mallari and against defendant Jun Miranda. The CA denied Miranda’s appeal
and affirmed the RTC Decision.
ISSUE:
Whether or not the CA erred when it did not award damages to Miranda.
RATIO DECIDENDI:
No. As to Miranda's claim for damages, the Petition has not alleged
sufficient factual basis to justify their award.
ART. 2176. Whoever by act or omission causes damage to another, there
being fault or negligence, is obliged to pay for the damage done. ART. 2180. The
obligation imposed by article 2176 is demandable not only for one's own acts or
omissions, but also for those of persons for whom — one is responsible.
Exclusive original jurisdiction in all civil actions which involve title to, or
possession of, real property, or any interest therein where the assessed value of the
property or interest therein does not exceed Twenty thousand pesos
(P20,000.00) or, in civil actions in Metro Manila, where such assessed value does
not exceed Fifty thousand pesos (P50,000.00) exclusive of interest, damages of
whatever kind, attorney's fees, litigation expenses and costs: Provided, That in
cases of land not declared for taxation purposes, the value of such property shall be
determined by the assessed value of the adjacent lots.