Esperanza Supapo v. Spouses Roberto

Summary

The Supreme Court reversed the lower courts' dismissal of an accion publiciana filed by registered landowners seeking to eject occupiers from their titled property. The key issues resolved were: (1) the Metropolitan Trial Court had proper jurisdiction because the property's assessed value (P39,980.00) fell below the P50,000.00 threshold for Metro Manila under RA No. 7691; (2) the cause of action to recover possession was imprescriptible under the Torrens system, as lands covered by registered titles cannot be acquired through prescription or adverse possession per Section 47 of PD No. 1529; and (3) res judicata did not apply because there was no identity of parties, subject matter, and causes of action between the previous criminal case under the Anti-Squatting Law and the civil action for recovery of possession. The decision reinforces the indefeasibility and imprescriptibility of Torrens titles, emphasizing that registered landowners retain the right to recover possession regardless of the length of unauthorized occupation. This case clarifies jurisdictional rules for accion publiciana and strengthens property rights protection under the Torrens system.