Case Digest (G.R. No. L-32192)
Facts:
The case of Esperanza Baptista, assisted by her husband, Arturo Villanueva vs. Urbano Carillo and the Hon. Court of Appeals revolves around a forcible entry dispute concerning a residential lot located in Quezon City. The case began on June 14, 1963, when Urbano Carillo filed a complaint against Esperanza Baptista, her husband Arturo Villanueva, and Atty. Loreto Abella in the Municipal Court of Quezon City, Branch III. Carillo had purchased the lot from the People's Homesite and Housing Corporation (PHHC) under a conditional contract of sale dated December 23, 1958. Following the purchase, Carillo took possession of the lot by fencing it with bamboo poles and barbed wire. However, in April 1963, he discovered that Baptista and Villanueva were constructing a structure on the lot without a building permit. Carillo reported this to the City Engineer, but no action was taken, prompting him to file the complaint. The Municipal Court ruled in favor of Carillo on December 6, 1...
Case Digest (G.R. No. L-32192)
Facts:
Background of the Case
- The case involves a forcible entry dispute over a residential lot (Lot 6, Block E-154, East Avenue Subdivision, Quezon City) awarded to respondent Urbano Carillo by the People's Homesite and Housing Corporation (PHHC) under a conditional contract of sale on December 23, 1958.
- Carillo took possession of the lot by fencing it with bamboo poles and barbed wire soon after the contract was executed.
Dispute Over Possession
- In April 1963, Carillo discovered two men constructing foundations for four posts on the lot without a building permit. He reported the matter to the City Engineer of Quezon City, but no action was taken.
- On June 14, 1963, Carillo filed a complaint for forcible entry against Esperanza Baptista, her husband Arturo Villanueva, and Atty. Loreto Abella in the Municipal Court of Quezon City.
Lower Court Decisions
- The Municipal Court ruled in favor of Carillo on December 6, 1963, ordering the defendants to vacate the lot and pay rentals for their possession.
- The Court of First Instance of Quezon City affirmed the decision on March 19, 1964, ejecting the defendants but dismissing the complaint against Atty. Abella and not awarding rentals.
- The Court of Appeals affirmed the lower court's decision on April 6, 1970.
Petitioners' Claims
- Petitioners (Baptista and Villanueva) claimed they had occupied the lot since 1956 and had preferential rights to acquire it.
- They argued that Carillo was disqualified from purchasing the lot because he was an American citizen and his wife already owned another PHHC lot.
Evidence Presented
- Petitioners submitted documents (e.g., communications to President Magsaysay, PHHC office orders, and Articles of Incorporation of Pinahan Homeowners' Association) to support their claim of prior possession. However, these documents were not presented during the trial and were deemed immaterial by the Supreme Court.
Issue:
- Whether the Court of Appeals erred in finding that petitioners occupied the lot only in May 1963, rather than 1956.
- Whether the Court of Appeals erred in upholding Carillo's right to possession of the lot.
- Whether the Court of Appeals erred in not recognizing petitioners' preferential rights to acquire the lot and in not disqualifying Carillo from purchasing it.
Ruling:
The Supreme Court affirmed the decision of the Court of Appeals, ruling in favor of Urbano Carillo. The petitioners were ordered to vacate Lot 6 and return possession to Carillo or his successors-in-interest.
Ratio:
- (Unlock)