Title
Altizo vs. BRYC-V Development Corp.
Case
G.R. No. 143530
Decision Date
Sep 26, 2006
SFC sold Lot 300-C to BRYC-V after a Letter of Intent with UMCUPAI. Petitioners, occupants since the 1960s, claimed rights but were denied by courts, affirming BRYC-V's ownership and right to possession.

Case Digest (G.R. No. 164805)

Facts:

  • Background of the Property and Ownership
    • Sea Foods Corporation Inc. (SFC) was the registered owner of a parcel of land known as Lot 300, covering 61,736 square meters at Seaside, Lower Calarian, Zamboanga City.
    • The property was covered by Transfer Certificate of Title (TCT) No. T-3182 (T-576), issued on September 21, 1939.
    • In the early 1960s, petitioners, namely Gellia Altizo and others, began occupying a portion of Lot 300.
  • Formation and Actions of UMCUPAI
    • In 1989, the petitioners along with other occupants of the property organized themselves into the United Muslim Christian Urban Poor Association, Inc. (UMCUPAI).
    • The purpose of forming UMCUPAI was to negotiate the acquisition of Lot 300 from SFC.
    • On October 4, 1991, SFC and UMCUPAI entered into a "Letter of Intent" wherein:
      • SFC declared its intention to sell Lot 300 to UMCUPAI at a price of P105.00 per square meter.
      • UMCUPAI declared its intention to purchase the property and undertook to raise the necessary funds.
      • The Letter of Intent stipulated that the execution of the Absolute Deed of Sale would be contingent upon full payment of the purchase price, and that the transfer of title and other pertinent documents would occur only thereafter.
  • Subdivision and Subsequent Sales of the Property
    • SFC subdivided Lot 300 into three lots: Lot 300-A, Lot 300-B, and Lot 300-C.
      • TCT Nos. T-117, 448; T-117, 449; and T-117, 450 were issued for Lots 300-A, 300-B, and 300-C, respectively.
    • On January 11, 1995, SFC sold Lot 300-A to UMCUPAI.
    • On July 20, 1995, SFC sold Lot 300-C to BRYC-V Development Corporation (BRYC-V), where petitioners had constructed their houses.
      • The sale was executed over the objection of UMCUPAI.
      • BRYC-V was subsequently issued Transfer Certificate of Title No. T-121,523 in its name.
  • Dispute Over Possession and Initiation of Legal Proceedings
    • BRYC-V, the new registered owner, demanded that petitioners vacate Lot 300-C both verbally and in writing.
    • Petitioners, refusing to vacate, remained in occupation.
    • Consequently, BRYC-V filed a complaint for unlawful detainer against petitioners before the Municipal Trial Court (MTC) in Zamboanga City.
    • The MTC rendered a judgment in favor of BRYC-V on November 11, 1996, finding petitioners to be deforciant occupants.
  • Judicial Proceedings and Appeals
    • The Regional Trial Court (RTC) of Zamboanga City, Branch 15, reversed the MTC decision.
      • The RTC held that the Letter of Intent effectively altered the status of petitioners’ occupation to one that granted UMCUPAI a right of first refusal or preferential right to acquire Lot 300-C.
    • BRYC-V elevated the case to the Court of Appeals.
      • On March 8, 1999, the Court of Appeals reversed the RTC decision.
      • The appellate court ruled that:
        • As the duly registered owner, BRYC-V was entitled to possession of Lot 300-C.
ii. Petitioners’ occupation was based merely on the previous owner SFC’s tolerance. iii. The Letter of Intent did not transfer ownership or possession but was only a manifestation of SFC’s intent to sell.
  • Petitioners’ subsequent motion for reconsideration was denied by the Court of Appeals on August 27, 1999.
  • Petitioners then filed the petition for review before the Supreme Court.

Issues:

  • Whether the Letter of Intent between SFC and UMCUPAI, which stated the intent to sell Lot 300 at a specified price, was sufficient to grant petitioners (as members of UMCUPAI) any possessory rights over Lot 300-C.
    • The issue centers on the nature of the Letter of Intent as a mere declaration of intent versus a binding contract that transfers ownership or confers a right of possession.
    • It was questioned if petitioners could rely on this document to continue their occupation of Lot 300-C despite the sale to BRYC-V.
  • Whether the actionable right to retain possession of Lot 300-C arises from merely occupying the property under the tolerated arrangement of a previous ownership, or if such rights are nullified once the property is sold and a title issued to a bona fide purchaser.
    • The legal implications concerning the transformation of mere tolerance into lawful possession were examined.
    • The issue also explored if the preferential right granted through the Letter of Intent could outweigh the rights of the subsequent registered owner.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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