G.R. No. L-50908 - Bautista vs. Juinio

In 2000, Abraham Chansuyco acquired a residential lot of 138 square meters located at 1306 Cadena de Amor St., Area A, Barangay Camarin, Caloocan City, covered by TCT No. C-346197.
Abraham was married to Elvira Rubio and died on November 26, 2002, leaving as heirs his wife Elvira and their children petitioners Claire Anne, Ronald Allan, and Abraham II.
The petitioners claim the property was their family home and that since 2003 they became estranged from their mother Elvira.
Petitioners learned that Elvira had turned over possession of the property to respondents Spouses Lope and Jocelyn Cervera Paltep.

Petitioners attempted to reclaim the property but respondents refused, asserting that Elvira had sold the property to them.
In 2004, petitioners purchased back 52 square meters of the property from respondents through an Absolute Deed of Sale to regain partial possession.
Petitioners argued that the property was a conjugal asset of their parents and that Elvira’s sale without liquidation violated Article 130 of the Family Code.
They also claimed that the sale infringed Articles 158 and 159 of the Family Code concerning the protection and consent relating to the family home.
Despite petitioners’ demand and a complaint initiated at the barangay level, respondents refused to vacate the property.

Respondents acquired the property from Elvira through a Deed of Sale dated February 2, 2004, for ₱500,000.
They later voluntarily relinquished 52 square meters to petitioners upon discovering Elvira lacked authority to dispose of the entire property.
They claimed petitioners challenged the possession and filed a complaint but failed to settle at the barangay level.
Respondents contended that nullifying the deed of sale was beyond the Metropolitan Trial Court (MeTC)'s jurisdiction.

Metropolitan Trial Court (MeTC) granted petitioners’ complaint for unlawful detainer, ordering respondents to vacate the premises. The MeTC held petitioners as co-owners had better right of possession; Elvira's sale was void due to lack of liquidation (Family Code Art. 130) and lack of consent (Arts. 158 and 159).
Regional Trial Court (RTC) partially granted respondents’ appeal: recognized co-ownership shares, treated Elvira’s conveyance as tacit liquidation only to the extent of her share, and ruled petitioners' ownership as 103.75 square meters. RTC suggested property partition to define metes and bounds.
Court of Appeals (CA) affirmed RTC decision with modification, directing petitioners either to refund ₱251,812 while respondents retained 34 sq.m. or pay ₱375,000 prompting respondents to vacate the property.

Petitioners filed a petition for review before the Supreme Court seeking reversal of the CA decision, contesting that Elvira’s sale prior to liquidation was void and that they did not consent to selling their family home.
Petitioners objected to refund orders to respondents.
Respondents adopted CA rulings in their comment dated February 8, 2014.

Did the complaint filed by petitioners sufficiently allege a cause of action for unlawful detainer, thereby conferring jurisdiction on the Metropolitan Trial Court?

Was the sale by Elvira of the conjugal property valid given the absence of liquidation and the petitioners’ lack of consent, considering Family Code Articles 130, 158, and 159?

Whether the Court of Appeals correctly modified the RTC decision concerning the refund to respondents and the co-ownership shares awarded.