Tuesday, January 22, 2019

Case Digest: Tamin vs. CA G.R. No. 97477 I May 8, 1992


FACTS:
The plaintiff (petitioner municipality herein) is the owner of a parcel of residential land located at Poblacion, Dumingag, Zamboanga del Sur with an area of 5,894 square meters more or less; that the parcel of land was reserved for public plaza under Presidential Proclamation No. 365 dated March 15, 1968; that during the incumbency of the late Mayor Isidoro E. Real, Sr. or in 1958, the municipality leased an Area of 1,350 square meters to the defendants (respondents herein) subject to the condition that they should vacate the place in case it is needed for public purposes; that the defendants religiously paid the rentals until 1967; that thereafter, the defendants refused to pay the rentals; that the incumbent mayor discovered that the defendants filed a "Cadastral Answer" over said lot; that the defendants refused to vacate the place despite efforts of the municipality; that the national government had alloted an appropriation for the construction of a municipal gymnasium within the public plaza but the said construction which was already started could not continue because of the presence of the buildings constructed by the defendants; that the appropriation for the construction of the gymnasium might be reverted back to the national government which would result to "irreparable damage, injury and prejudice" to the municipality and its people who are expected to derive benefit from the accomplishment of the project.

The trial court granted the petitioner municipality's motion for a writ of possession "with the ancillary writ of demolition to place in possession the plaintiff on the land subject of this case, to the end that the public construction thereon will not be jeopardized."

ISSUE:
(1) Whether or not the issuance of the writ of possession and ancillary writ of demolition was proper; and (2) Whether or not the buildings constructed by the respondents are nuisance.

DECISION:
The issuance of the writ of possession and ancillary writ of demolition was improper because an administrative case on the ownership of the land to which the respondent is a party-in-interest is still pending. Thus, should the respondent be declared the rightful owner of the land, the demolition shall be prejudicial to his interest.

The buildings constructed by the respondents shall be considered a nuisance should the pending administrative case declare that the subject land is part of public dominion. The Civil Code provides under Art. 694 that “A nuisance is any act, omission, establishment, business, condition of property or anything else which... (5) Hinders or impairs the use of property." Thus, if the administrative case is decided against the respondent, his continued use of the buildings hinders or impairs the use of the property by the municipality making such building a nuisance.

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