Petitioner
Francisco Gutierrez Repide
Respondent
Martin Astuar
Citation
G.R. No. 505
Court
Supreme Court En Banc
Division
En Banc
Ponente
Willard, J.
Decided
April 8, 1902

Summary

The Philippine Sugar Estates Development Company sought judicial possession of two large estates through Title XIII proceedings. When over 200 tenant-occupants formally objected, the Court of First Instance declared the matter contentious. The Supreme Court affirmed, establishing the crucial principle that voluntary jurisdiction proceedings for judicial possession must become contentious when occupants object. The Court held that bare possessors have the right to be respected in their possession under Article 446 of the Civil Code, and cannot be dispossessed without being heard in court. This landmark 1902 decision clarified the relationship between voluntary and contentious proceedings in property possession cases, emphasizing due process rights of occupants.

Statutes applied

By Intellegal Editorial Board · April 8, 1902

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