G.R. No. 149927 - Republic vs. Rosemoor Mining and Development Corporation

The case involves a parcel of land identified as Lot 202-F-13 under Transfer Certificate of Title No. T-34254 in Davao City, which is co-owned by the petitioners.
On the lot stands a house originally occupied under a verbal lease arrangement at P25.00 monthly rental with defendant Francisco Ang Singco, itself a co-lessee.

In July 1977, without the knowledge or consent of the co-owners, defendant Ang Singco sold the house to his co-defendants, Federico and Carmen Laurecio.
Petitioners, upon discovery of the sale (and having been informed during a visit by Marietta Dakudao), objected to the transactions, asserting that the sale was executed with stealth, particularly since Ang Singco was already in arrears for one year and seven months.

After the sale, the Laurecios took possession of the property and occupied the house. Petitioners demanded that they vacate the premises and pay P100.00 per month as compensation for the use and occupation.
The Laurecios, however, were willing to settle at P50.00 per month, leading to a breakdown of any agreement.

The City Court of Davao City initially dismissed the unlawful detainer case against the Laurecios, holding that no lease—express or implied—existed between the petitioners and the Laurecios, and that the remedy against defendant Ang Singco was converted into a claim solely for back rentals.
The Court of First Instance of Davao initially modified the City Court’s decision, ruling that an implied lease was created by the petitioners’ demand for rental payment, thus permitting an action for unlawful detainer against the Laurecios.
Upon motion for reconsideration by the private respondents, the CFI set aside its modified decision, reverting to the City Court’s position that no lease (express or implied) existed and that the proper remedy did not lie in an unlawful detainer action.
The petitioners then elevated the case to the Supreme Court on pure questions of law, arguing that an implied promise existed whereby the tolerated occupation imposed an obligation on the respondents to vacate when demanded.

Whether an express or implied lease contract was created between the co-owners (petitioners) and the Laurecios.
If no such contract exists, whether the doctrine of implied promise arising from the owner’s tolerance of the occupation can validate an unlawful detainer action.

Whether an action for unlawful detainer is the proper remedy against the Laurecios, who occupy the premises on a basis of mere tolerance.
Whether the alleged strategy and stealth in evading the petitioners’ knowledge of the sale and subsequent occupation can alternatively justify a case for forcible entry or ejectment.

Whether Article 1649, which restricts the lessee from assigning the lease without the owner’s consent, bars the Laurecios from being deemed lawful successors-in-interest.
How the absence of explicit consent or agreement impacts the interpretation of lawful possession and the remedies available to the petitioners.

Whether the delay or alleged tolerance in demanding vacatur – from the initial discovery to the formal letter sent – should be treated as an estoppel or waiver of the petitioners’ rights.
The impact of procedural technicalities on substantive justice in evicting persons who occupy land without a solid contractual basis.