Title
Aznar Brothers Realty Co. vs. Court of Appeals
Case
G.R. No. 128102
Decision Date
Mar 7, 2000
AZNAR acquired Lot No. 4399 via a valid deed; private respondents, claiming ancestral rights, contested ownership. Courts upheld AZNAR's title, ruling prior possession unnecessary in unlawful detainer cases. SC reversed CA, reinstating RTC's eviction order.
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Case Digest (G.R. No. 128102)

Facts:

  1. Acquisition of Lot No. 4399 by AZNAR

    • Petitioner Aznar Brothers Realty Company (AZNAR) acquired Lot No. 4399, located in Brgy. Mactan, Lapu-Lapu City, from the heirs of Crisanta Maloloy-on through an Extrajudicial Partition of Real Estate with Deed of Absolute Sale dated March 3, 1964. The deed was registered on March 6, 1964.
    • AZNAR declared the property under its name for taxation purposes and regularly paid taxes thereon.
  2. Private Respondents' Occupation of the Land

    • Private respondents (Luis Aying, Demetrio Sida, Felomino Augusto, Federico Abing, and Romeo Augusto) claimed to be descendants of Crisanta Maloloy-on and alleged that they had been occupying the land in the concept of owners since the time of their parents and grandparents.
    • They contended that the Extrajudicial Partition with Deed of Absolute Sale was void ab initio for being simulated and fraudulent. They only became aware of the alleged fraud when AZNAR entered the land in 1991 and destroyed its vegetation.
  3. Legal Proceedings

    • AZNAR filed an unlawful detainer case (Civil Case No. R-1027) in the Municipal Trial Court (MTCC) of Lapu-Lapu City, seeking to evict the private respondents.
    • The MTCC ruled in favor of AZNAR, ordering the private respondents to vacate the land and pay attorney’s fees and litigation expenses.
    • Private respondents appealed to the Regional Trial Court (RTC), which affirmed the MTCC’s decision and issued a writ of demolition.
    • The Court of Appeals reversed the RTC’s decision, declaring the private respondents as rightful possessors de facto and permanently enjoining the demolition of their houses.
  4. Issues Raised by AZNAR

    • AZNAR challenged the Court of Appeals’ decision, arguing that the MTCC and RTC decisions were final and executory, that prior physical possession was not required in unlawful detainer cases, and that the Extrajudicial Partition with Deed of Absolute Sale was valid.

Issue:

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Ruling:

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Ratio:

  1. Finality of Judgments in Ejectment Cases

    • The filing of an appeal stays the execution of a judgment in ejectment cases unless back rentals or damages are awarded, in which case a supersedeas bond is required. Since no such amounts were awarded here, the MTCC decision did not become final and executory.
  2. Possession in Unlawful Detainer Cases

    • Prior physical possession is not a prerequisite in unlawful detainer cases. The plaintiff’s cause of action is to terminate the defendant’s possession, not to recover prior possession.
  3. Validity of Notarized Documents

    • Notarized documents enjoy a presumption of regularity and due execution. Allegations of fraud or forgery must be proven by clear and convincing evidence, which the private respondents failed to do.
  4. Estoppel and Ownership Claims

    • Estoppel does not apply when the statements in question are taken out of context or do not directly contradict the party’s claim of ownership.
  5. Equitable Suspension of Writ of Demolition

    • Once a writ of demolition has been implemented, the issue of suspending its enforcement becomes moot. Equitable reasons for suspension are no longer applicable after the act sought to be enjoined has been accomplished.

Conclusion:

The Supreme Court granted AZNAR’s petition, reversing the Court of Appeals’ decision and reinstating the RTC’s ruling. The Extrajudicial Partition with Deed of Absolute Sale was upheld as valid, and the private respondents were ordered to vacate the property. The Court emphasized that the issue of possession in ejectment cases is provisional and does not preclude a final determination of ownership in a separate action.


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