G.R. No. 223852 - Aleguela vs. Eastern Petroleum Corp.

The petitioners – Edna Roque Aleguela, Felipe Gonzales, Dolores Cochesa, Luisa Cagalingan, Reynaldo Junsay, Bonifacia Rodriguez, Coney Cerdena, and all persons claiming rights under them – were occupying certain parcels of land situated at J. B. Miguel Street, Barangay Bambang, Pasig City.
The disputed properties were registered under the names of the respondents, Eastern Petroleum Corporation and J&M Properties and Construction Corporation, following a Deed of Absolute Sale dated January 27, 2006.

The subject properties were originally covered by one title (TCT No. 314548) and later subdivided into separate certificates of title: Title No. PT-130608 for Eastern Petroleum and Titles No. PT-140851 and PT-140844 for J&M Properties.
The issuance of separate titles occurred after the respondents presented the deed, and the Register of Deeds acted thereupon.

The petitioners asserted that they had been occupying the disputed lots for more than 50 years.
They claimed that prior to the sale of the lots, they were afforded a right of first refusal under the Urban Land Reform Act as embodied in Presidential Decree (P.D.) No. 1517 and the protective provisions of P.D. No. 2016.
Their contention was that the respondents’ acquisition and subsequent registration of title violated their rights as legitimate occupants who had, allegedly, established tenancy through a long-standing relationship with the previous landowners.

The respondents initiated ejectment suits before the Metropolitan Trial Court (MeTC) of Pasig City, which were dismissed.
A subsequent action for recovery of possession with damages was filed with the Regional Trial Court (RTC) of Pasig City.
In their defense, the petitioners claimed their continuous occupation for decades; however, during trial, their counsel failed to appear and submit a judicial affidavit, leading the RTC to declare them as having waived their right to present evidence.
Only two co-defendants, Placido “Eddie” Cagalingan and Avelino Flores, managed to submit additional evidence to substantiate claims of tenancy.

The RTC, on June 11, 2014, rendered a decision ordering the petitioners to vacate the premises and to pay reasonable monthly compensation from November 2009 until actual surrender, with no order on costs.
The RTC denied the petitioners’ motion for reconsideration on August 27, 2014.
The Court of Appeals (CA) affirmed the RTC decision on April 6, 2016, finding that the petitioners had failed to prove a valid contractual basis for tenancy as required by Section 3(f) of P.D. No. 1517.

The petitioners filed a petition for review on certiorari, arguing that their possession was based on a lease contract with the former owner (Carlos L. Asuncion, his heirs and successors) and that they should have been afforded the right of first refusal under pertinent statutes.
They contended that a review was warranted to re-examine the factual determinations made by the lower courts regarding their tenancy status, despite the lower courts’ findings that their possession was by mere tolerance rather than constituting a legally binding lease.

Whether continuous possession for more than 50 years automatically qualifies the petitioners as legitimate tenants under the protective provisions of P.D. No. 1517 and P.D. No. 2016.
Whether the petitioners fulfilled the legal requirements to be considered tenants, specifically the presentation of evidence evidencing a contract of lease with the previous owners.

Whether the failure of the petitioners to present sufficient documentary evidence (i.e., a valid lease agreement) was rightly held against them in determining their status as tenants.
Whether the declaration of waiver by the court for failing to present evidence should preclude reconsideration of their tenancy claim.

Whether the petitioners’ appeal raised questions of fact that should be re-examined by the Supreme Court.
Whether the issues presented fall within the ambit of questions of law only, thereby limiting the reviewing function of the Court.