G.R. No. 142843 - Alvarez vs. Court of Appeals

On May 15, 1978, spouses Domingo and Celia Garcia purchased a parcel of land identified as Lot 23, Block 6, San Beda Subdivision, Visayas Avenue, Quezon City, with an area of 405 square meters.
The property was registered under Transfer Certificate of Title (TCT) No. 221634, and subsequently a new TCT was issued in their name.
The Garcías proceeded to fence the property before traveling to the United States for Domingo’s employment.

Upon her return to the Philippines in February 1995, Celia Garcia observed that the fence on the lot had been removed and portions of the property were occupied by persons who had constructed houses of light materials.
During a confrontation at the barangay level, some of the occupants identified themselves as Marilyn Cortez and Charlie Robles, asserting that they were leasing the property from a certain Octavio Alvarez, who allegedly acquired the lot from Amparo Lasam.
The inability of the parties to reach an amicable settlement prompted the Garcías to file a complaint for forcible entry against the occupants, which was later amended to implead Octavio Alvarez, Charlie Robles, and Marilyn Cortez.

The Metropolitan Trial Court (MeTC) of Quezon City rendered a decision on November 11, 1997, ordering Alvarez, Robles, and Cortez to vacate the property; the decision also mandated:

Immediate vacation of the premises.
Removal of any structures or improvements.
Payment of ₱20,000 per month to the plaintiffs as compensation, computed from August 1995 until complete vacation.
Payment of ₱20,000 for attorney’s fees.
Payment of the costs of suit.

Petitioners filed a notice of appeal on January 14, 1998, before the Regional Trial Court (RTC) of Quezon City, Branch 227.
In the interim, respondents sought a writ of execution, and a writ of demolition was subsequently issued when petitioners failed to appear at the scheduled hearing. This writ later became the subject of a separate petition for certiorari pending before RTC Branch 217.

On April 28, 1999, the RTC of Quezon City, Branch 227, affirmed the MeTC decision.
Petitioners then elevated the case to the Court of Appeals, filing a petition for review on the ground that the lower courts failed to appreciate properly the evidence presented by them.
On January 26, 2000, the Court of Appeals denied the petition, dismissing it with costs against the petitioners, which was followed by a motion for reconsideration that was denied on April 10, 2000.

Departed from the accepted course of proceeding by ruling on the issue of ownership in an ejectment case, where the primary issue is possession de facto, not de jure.
Erred by not giving effect to their evidence showing prior physical possession and ownership of the disputed property.
Failed to credit the probative value of their documents, such as the deed of sale executed by respondent’s attorney-in-fact (Renato Garcia) and the special power of attorney authenticated by the US Consul, which allegedly established their ownership advantage.
Erroneously approved the issuance of a writ of demolition without proper compliance with the rules governing motions for demolition.

Petitioners further argued that Alvarez, as an innocent purchaser for value, should have been afforded protection regarding his purported title over the property.

Respondents maintained that the issue of possession in ejectment cases is inherently intertwined with that of ownership when such is raised as an affirmative defense.
They contended that the Court of Appeals correctly resolved the issue by giving due weight to the evidence on record showing respondents as the true owners.
Respondents argued that Alvarez, being educated and informed, should have noted any defects in the title when acquiring the property, negating any claim of being an innocent purchaser.
Lastly, respondents asserted that the propriety of the writ of demolition is properly addressed in a separate pending case and that to raise it in this petition would constitute forum shopping.

Whether the Court of Appeals and the lower courts erred in ruling on the issue of ownership in a forcible entry (ejectment) case where the determinant issue is generally physical possession de facto.
Whether the Court of Appeals should have given effect to petitioners’ evidence demonstrating that they had prior physical possession and ownership of the disputed property over the private respondents.
Whether the Court of Appeals committed an error in refusing to accord sufficient probative value to the documents submitted by petitioners, notably the deed of sale and the special power of attorney, purportedly proving their ownership.
Whether the issuance of the writ of demolition by the trial court was irregular due to non-compliance with the requisite procedural rules for litigated motions.