Case Digest (G.R. No. 143530)
Facts:
The case involves Gellia Altizo and several other petitioners, including spouses Abelardo and Marita "Nenita" Ambrona, spouses Carlos and Nora Apalad, and spouses Alvin and Judy Apalad, as petitioners against Bryc-V Development Corporation (BRYC-V) as the respondent. The events leading to the case began with Sea Foods Corporation Inc. (SFC) being the registered owner of a parcel of land identified as Lot 300, covering an area of 61,736 square meters located in Seaside, Lower Calarian, Zamboanga City, under Transfer Certificate of Title No. T-3182 (T-576), issued on September 21, 1939. In the early 1960s, the petitioners began occupying a portion of Lot 300. In 1989, they, along with other occupants, formed the United Muslim Christian Urban Poor Association, Inc. (UMCUPAI) to negotiate for the acquisition of Lot 300. On October 4, 1991, SFC and UMCUPAI entered into a "Letter of Intent to Sell," wherein SFC expressed its intention to sell Lot 300 to UMCUPAI ...
Case Digest (G.R. No. 143530)
Facts:
Ownership and Initial Occupation
- Sea Foods Corporation Inc. (SFC) was the registered owner of Lot 300, a 61,736-square-meter parcel of land in Lower Calarian, Zamboanga City, covered by Transfer Certificate of Title No. T-3182 (T-576) issued on September 21, 1939.
- In the early 1960s, petitioners Gellia Altizo and others began occupying a portion of Lot 300.
Formation of UMCUPAI and Letter of Intent
- In 1989, petitioners and other occupants of Lot 300 organized the United Muslim Christian Urban Poor Association, Inc. (UMCUPAI) to negotiate the acquisition of the lot.
- On October 4, 1991, SFC and UMCUPAI entered into a "Letter of Intent to Sell by Landowner and Letter of Intent to Purchase by the UMCUPAI." The agreement stated:
- SFC intended to sell Lot 300 to UMCUPAI at P105.00 per square meter.
- UMCUPAI declared its intention to buy the property and raise the necessary funds.
- The Absolute Deed of Sale would be executed upon full payment.
Subdivision and Sale of Lot 300
- SFC later subdivided Lot 300 into three lots: Lot 300-A, Lot 300-B, and Lot 300-C.
- On January 11, 1995, SFC sold Lot 300-A to UMCUPAI.
- On July 20, 1995, SFC sold Lot 300-C, where petitioners had constructed their houses, to BRYC-V Development Corporation (respondent). Respondent was issued Transfer Certificate of Title No. T-121,523.
Dispute and Legal Proceedings
- Respondent demanded that petitioners vacate Lot 300-C, but they refused.
- Respondent filed a complaint for unlawful detainer against petitioners before the Municipal Trial Court (MTC) in Zamboanga City.
- The MTC ruled in favor of respondent on November 11, 1996.
- On appeal, the Regional Trial Court (RTC) reversed the MTC decision, holding that respondent was bound by the Letter of Intent, which granted UMCUPAI a preferential right to buy Lot 300-C.
- The Court of Appeals reversed the RTC decision on March 8, 1999, ruling that respondent, as the registered owner, was entitled to possession, and the Letter of Intent did not transfer ownership or possession to petitioners.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Possession Based on Tolerance: Petitioners' possession of Lot 300-C was merely tolerated by SFC and did not confer any legal right to remain on the property after its sale to respondent.
- Effect of the Letter of Intent: The Letter of Intent was not a binding contract of sale but a mere expression of intent. It did not create any enforceable right of possession or ownership in favor of petitioners.
- Registered Owner's Right to Possession: As the registered owner of Lot 300-C, respondent is entitled to its possession to the exclusion of petitioners, who are deforciant occupants.