Facts:

The case involves a petition for review filed by Valentin Cabrera, Manuel Cabrera, and Rebecca Leslie Cabras (petitioners) against Elizabeth Getaruela, Eulogio Ababon, Leonida Ligan, Marietto Ababon, Gloria Panal, Leonora Ocariza, Sotero Ababon, Jr., and Joseph Ababon (respondents). The events leading to the case began with Lot Nos. 3635-CC and 3635-Y in Inayawan, Pardo, Cebu City, which were covered by Tax Declaration Nos. GR2K-12-078-02409 and GR2K-12-078-02431 in the name of Arcadio Jaca. On July 25, 1951, the heirs of Arcadio executed a notarized document called "Kasabutan nga Hinigala," which stated that all inherited properties, including Lot No. 3635, would be transferred to Peregrina Jaca Cabrera. However, a Repartition Project approved on November 21, 1956, by Judge Jose M. Mendoza of the Court of First Instance of Cebu City, allocated Lot Nos. 3635-CC and 3635-Y to Urbana Jaca Ababon, the mother of the respondents. After Urbana's death in 1997, the res...

Facts:

Antecedent Property Details

• The properties in controversy were Lot Nos. 3635-CC and 3635-Y, located in Inayawan, Pardo, Cebu City, originally covered by Tax Declaration Nos. GR2K-12-078-02409 and GR2K-12-078-02431 in the name of Arcadio Jaca.
• After Arcadio’s death, his heirs executed a notarized document known as the "Kasabutan nga Hinigala" on 25 July 1951, stipulating that all of Arcadio’s inherited properties, including Lot No. 3635, should be transferred to Peregrina Jaca Cabrera.

The Repartition Project and Chain of Title

• In a Repartition Project approved on 21 November 1956 by Judge Jose M. Mendoza of the Court of First Instance of Cebu City, Branch 6 – in Special Proceedings No. 211-V – Lot Nos. 3635-CC and 3635-Y were allocated to Urbana Jaca Ababon, mother of the respondents (Elizabeth Getaruela, Eulogio Ababon, Leonida Ligan, Marietto Ababon, Gloria Panal, Leonora Ocariza, Sotero Ababon, Jr., and Joseph Ababon).
• Upon Urbana’s death in 1997, the respondents inherited the lots. Petitioners, namely Valentin Cabrera, Manuel Cabrera, and Rebecca Leslie Cabras (Peregrina’s adopted daughter), occupied the lots with the knowledge and consent of the respondents.

Occupation and Dispute Over Possession

• Petitioners occupied portions of the lots without paying rentals, under an arrangement that they would vacate and demolish any structures at their own expense if respondents needed the property.
• In 2001, respondents personally notified petitioners to vacate the premises and remove their houses. Despite repeated demands and an attempt at an amicable settlement through the Lupong Tagapamayapa of Barangay Inayawan, petitioners refused to vacate the property.

Trial Court Proceedings and Document Disputes

• The case was initially filed as an ejectment action (Civil Case No. R-45280) in the Municipal Trial Court in Cities (MTCC), Branch 7, Cebu City.
• In its April 4, 2002 Decision, the MTCC ruled in favor of respondents, ordering petitioners to vacate and demolish any improvements, and noting that the court-approved Repartition Project superseded the "Kasabutan nga Hinigala".
• Petitioners appealed the MTCC’s Decision to the Regional Trial Court (RTC) of Cebu City, Branch 7.
• On 19 May 2003, the RTC reversed the MTCC’s ruling by holding that the Project of Partition indicated co-ownership arrangements which prevented the ejectment of petitioners from at least part of the property.
• The RTC’s reversal was based on findings that the Project of Partition showed Lot No. 3635-Y to be jointly owned by Urbana, Peregrina, and Andres Jaca, and that petitioners had occupied the lot with permission.
• Subsequent Developments in the RTC
• Respondents filed a motion for reconsideration, and on 29 July 2003 the RTC partially granted it by modifying its earlier decision – dismissing the complaint as to Lot 3635-Y and ordering petitioners to vacate Lot No. 3635-CC.
• Petitioners’ motion for reconsideration on 3 September 2003 was denied, with the RTC holding that they failed to provide evidence to challenge the validity of the Project of Partition.

Appellate Court Proceedings

• Petitioners elevated the case to the Court of Appeals, challenging the jurisdiction of the MTCC, the character of the ejectment action, and the validity of the Project of Partition vis-à-vis the "Kasabutan nga Hinigala".
• In its 22 January 2004 Decision, the Court of Appeals affirmed the RTC’s orders, holding:
• The jurisdiction of the MTCC is proper even in the absence of a formal lease contract, as the complaint alleged wrongful holding by petitioners based on toleration and subsequent illegal occupation following notice by respondents.
• The issue of possession remains the primary focus, and allegations surrounding title are only pertinent for determining who has the right to possess the property on a provisional basis.
• Petitioners’ motion for reconsideration in the Court of Appeals, filed on 3 May 2004, was denied, with the Court reiterating that the proper cause of action for unlawful detainer is determined by the commencement of illegal possession upon demand and that any determinations regarding ownership are provisional for resolving possession issues.

Issue:

Jurisdiction

• Whether the MTCC had jurisdiction to entertain the ejectment case even though there was no expressed contract—written or oral—between respondents and petitioners as lessors and lessees.
• Whether the proper remedy should have been a recovery of possession action rather than an unlawful detainer suit.

Grounds for Ejectment

• Whether the doctrine of tolerance, wherein petitioners initially occupied the property with the consent of respondents, could serve as a basis for ejectment once respondents demanded possession and petitioners refused to vacate.
• Whether petitioners’ occupation, though initially consensual, became illegal upon their refusal to vacate after respondents’ demand.

Evidentiary and Document Authenticity Issues

• Whether the Project of Partition, which is central to establishing the respondents’ claim to the property, superseded the earlier "Kasabutan nga Hinigala".
• Whether deficiencies in the Project of Partition (such as the missing first page and lack of signatures) affected its validity.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)