Title
Dela Cruz vs. Court of Appeals
Case
G.R. No. 139442
Decision Date
Dec 6, 2006
Long-term tenant refuses to vacate after property sale; SC upholds ejectment, ruling possession by tolerance became unlawful post-demand.

Case Digest (G.R. No. 27026)

Facts:

  • Background and Parties
    • The Reyes family, represented by Mr. Lino Reyes, owned a lot located at No. 1332 Lacson Street, Sampaloc, Manila.
    • Petitioner Lourdes Dela Cruz was a longtime lessee, paying rent over a portion of the lot for over 40 years.
    • In 1989, a fire destroyed petitioner’s dwelling on the property.
  • Post-fire events and demands to vacate
    • After the fire, petitioner and other tenants returned and rebuilt their houses on the lot.
    • The Reyes family verbally demanded tenants including petitioner to vacate the lot; petitioner refused.
    • On February 21, 1994, petitioner was served a written demand to vacate but still refused.
    • The Reyes family did not file court action after the 1994 demand.
  • Sale of property and further demands
    • On November 26, 1996, the Reyes family sold the lot to respondent Melba Tan Te, who intended to use it for residential purposes.
    • Petitioner did not vacate after sale; a written demand was sent to her on January 14, 1997, which she also ignored.
    • Respondent Tan Te initiated conciliation at the barangay level; petitioner asked for Php 500,000 for her house, which respondent rejected as unconscionable.
    • A certificate to file action was issued, prompting Tan Te to file ejectment proceedings.
  • Judicial proceedings
    • On September 8, 1997, respondent Tan Te filed an ejectment complaint in the Manila MeTC (Civil Case No. 156730-CV), alleging forcible entry and unlawful withholding of possession by petitioner.
    • Petitioner answered on October 24, 1997, denying jurisdiction of MeTC and claiming protection as a rent-paying tenant under PD 20, asserting her lease was a legal encumbrance, and raising the issue of pending expropriation.
  • Lower court decisions
    • The Manila MeTC ruled in favor of respondent Tan Te on April 3, 1998, ordering petitioner to vacate, pay monthly rent and attorney’s fees.
    • Petitioner appealed to the Manila Regional Trial Court (RTC), which on September 1, 1998, reversed the MeTC ruling, dismissing Tan Te’s complaint for lack of jurisdiction, reasoning the ejectment suit was filed beyond one year and was thus an accion publiciana subject to RTC jurisdiction.
    • Respondent Tan Te appealed to the Court of Appeals (CA), which on April 30, 1999, reversed the RTC decision and reinstated the MeTC ruling.
    • Petitioner’s motion for reconsideration was denied by the CA on July 16, 1999.
  • Present petition
    • Petitioner filed a Petition for Review on Certiorari before the Supreme Court seeking to nullify the CA decisions.

Issues:

  • Whether the Court of Appeals erred:
    • By going beyond the issues properly raised in the case, contrary to the trial court findings.
    • By reversing the RTC decision and reinstating the MeTC ruling, despite purported contradiction with evidence.
  • Jurisdictional issue:
    • Whether the Manila MeTC or the Manila RTC has jurisdiction over the ejectment suit filed by respondent Tan Te.
  • Whether petitioner’s possession was lawful or unlawful, affecting the propriety of the ejectment suit.
  • Ancillary issue:
    • Whether the passage of Manila City Ordinance No. 7951 concerning intended expropriation of the disputed lot affects the ejectment case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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