Facts:

The case revolves around a dispute between Bienvenido Barrientos (petitioner) and Mario Rapal (respondent) concerning a 235 square meter parcel of land located at No. 2 Misamis St., Luzviminda Village, Barangay Batasan Hills, Quezon City. Respondent Mario Rapal acquired the parcel of land from Antonio Natavio on April 15, 1988, through a notarized Deed of Transfer of Possessory Right, which was reportedly part of the estate of the late Don Mariano San Pedro y Esteban, covered by Original Certificate of Title No. 4136. After acquiring the property, Rapal constructed a semi-concrete house and took possession of the lot. In 1993, he allowed Barrientos and his family to stay on the property as caretakers, under the agreement that Barrientos would vacate upon request. However, when Rapal demanded Barrientos vacate the premises by July 14, 1997, Barrientos refused. Following failed attempts at barangay conciliations, Rapal filed a case for Unlawful Detainer against Barrientos on April

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Facts:

Acquisition and Development of the Property

• On April 15, 1988, respondent Mario Rapal acquired a 235-square-meter parcel of land located at No. 2 Misamis St., Luzviminda Village, Barangay Batasan Hills, Quezon City.
• The acquisition was executed via a notarized Deed of Transfer of Possessory Right from Antonio Natavio.
• The land was described as a portion of the estate of the late Don Mariano San Pedro y Esteban, originally covered by Original Certificate of Title (OCT) No. 4136.

Construction, Possession, and Occupation

• Respondent constructed a semi-concrete house on the lot.
• Respondent took actual possession of the property personally and through his caretaker, Benjamin Tamayo.

Caretaker Arrangement and Subsequent Conflict

• Around 1993, respondent allowed petitioner Bienvenido Barrientos and his family to stay on the property as caretakers, under the understanding that their occupancy would be temporary and that they would vacate upon respondent’s demand.
• The petitioner, however, refused to vacate the property when respondent made his last demand on July 14, 1997.
• Attempts at resolving the matter through barangay conciliations were unsuccessful.

Initiation of Legal Proceedings and Decisions in Lower Courts

• On April 13, 1998, respondent filed an Unlawful Detainer case against petitioner Bienvenido Barrientos before the Metropolitan Trial Court (MeTC) of Quezon City, docketed as Civil Case No. 19889.
• On February 21, 2000, the MeTC rendered a decision in favor of the respondent ordering the petitioner to vacate the property and awarding damages (P3,000 per month as compensation plus additional sums for attorney’s fees and costs).

Reversal by the Regional Trial Court (RTC)

• The RTC reversed the MeTC decision, ruling in favor of petitioner on the basis that respondent had not demonstrated any prior lawful possession of the property.
• The RTC’s decision explicitly found no basis to award any counterclaim in favor of the respondent.

Court of Appeals (CA) Decision and Reinstatement of Lower Court Ruling

• On April 29, 2005, the CA reversed the RTC’s decision, thereby reinstating the decision of the MeTC in favor of respondent.
• The CA’s decision was based on a comparative analysis of which party was first in possession, with evidence indicating that respondent was the one in prior possession of the lot.
• A motion for reconsideration filed by the petitioner was later denied in a Resolution dated September 1, 2005.

Issues Raised on Appeal and the Nature of the Dispute

• The petition raised questions regarding the resolution of the issue of ownership merely to decide who had the right to possess the property.
• It also questioned whether the respondent’s notarized document purporting to be a transfer of possessory right should prevail over the petitioner’s claim based on actual possession and a Certificate of Project Qualification.
• The case was contextualized within the framework of unlawful detainer and ejectment actions, which focus on physical or de facto possession irrespective of the underlying title.

Issue:

• Whether the issue of ownership may be initially resolved for the purpose of determining "who is entitled to physical possession" of the property in an unlawful detainer proceeding.
• Whether the respondent’s document, which purported to effect a transfer of possessory rights, should prevail over the petitioner’s claim to actual possession and alleged ownership rights, particularly considering the petitioner’s Certificate of Project Qualification from a government agency.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)