G.R. No. 132922 - Telecommunications and Broadcast Attorneys of the Philippines, Inc. vs. Commission on Elections

The case involves Marvin A. Galacgac as petitioner (substituted heir of Benigno M. Galacgac) and Reynaldo Bautista as respondent.
The dispute centers on a 180‑square meter portion of Lot No. 10973 in Laoag City.
The origin of the dispute is traced back to events in 1993 when the heirs of Ines Mariano (Cirila Dannug-Martin, Maxima Dannug-Dannug, Arcadia Dannug-Pedro, and Isabel Dannug-Bulos) partitioned and adjudicated the disputed area in favor of Benigno M. Galacgac pursuant to a contingency fee agreement related to his legal services.

Benigno allegedly permitted Saturnino Bautista, the caretaker for the heirs, to occupy the land on condition that Saturnino construct a house of light materials and surrender possession if needed.
Reynaldo Bautista, son of Saturnino, initiated construction on a house made of strong materials, which was contrary to the supposed agreement.
Benigno sent demand letters to Reynaldo urging deferral of construction and to vacate the premises, asserting that the permission extended was not valid for Reynaldo.

In 2012, Benigno M. Galacgac filed an action for unlawful detainer in the Municipal Trial Court in Cities (MTCC) of Laoag City.

The MTCC dismissed the complaint, basing its decision on the finding that Reynaldo’s possession derived from the rightful authority of the heirs (Cirila, Maxima, Arcadia, and Isabel) rather than from any act of tolerance by Benigno.
The MTCC emphasized that the alleged agreement was not supported by any written contract and that the defendant’s possession was thus not based on an implied promise to relinquish or vacate on demand.

Before the RTC rendered its decision, Benigno deceased, and his heir Marvin A. Galacgac substituted as the petitioner.
The RTC reversed the MTCC’s dismissal by ordering Reynaldo to surrender possession, finding that Benigno had a better right based on the adjudication of the land long before Reynaldo’s sale claim.

On May 18, 2015, the CA reinstated the MTCC’s decision dismissing the complaint.
The CA held that Benigno failed to prove an initial act of tolerance regarding Reynaldo’s occupation—a critical element to sustain a cause of action for unlawful detainer.

Marvin subsequently sought reconsideration of the CA decision, but the petition for review on certiorari under Rule 45 was ultimately resolved with dismissal of the complaint for lack of cause of action.

The complaint acknowledged that permission was extended to Saturnino (the caretaker) but made no clear allegation that such tolerance was ever extended directly to Reynaldo.
Testimony regarding the alleged tolerance was weakened by the fact that Saturnino had died prior to the filing of the case, rendering any testimony about his actions inadmissible.
Evidence indicated Reynaldo claimed a title originating from alleged sales by Maxima and Arcadia, thereby contesting any claim of mere possession based on tolerance from Benigno.
The summary action for ejectment was shown to be inappropriate in this context since the essential act of tolerance was not properly established as required.

Whether the complaint for unlawful detainer sufficiently alleged and proved that Reynaldo’s possession began with an act of tolerance (permission) by Benigno.
Whether such tolerance was present from the very start, as required for establishing an implied promise to vacate upon demand.

Whether the evidence presented supported an implied contractual arrangement defining the conditions of possession.
Whether the alleged permission extended to Saturnino could be imputed to Reynaldo, who later began constructing a building of strong materials.

Whether summary ejectment under a claim of unlawful detainer is proper in situations where the alleged tolerance is unsubstantiated.
Whether a summary proceeding can be used to oust a possessor when the foundational act of tolerance is merely alleged without clear evidentiary support.