G.R. No. 255989 - Galande vs. Espiritu-Sarenas

The subject property is a 4,606-square-meter parcel of land located in Brgy. Pinili, San Jose City, Nueva Ecija, covered by Transfer Certificate of Title (TCT) No. 21865 and registered in the name of Spouses Salamanca.
Petitioner Rodrigo Galande claimed actual and continuous possession of the property for over 40 years as a tenant of the Salamancas and later purchased the property from them on an installment basis for P950,000.00.
Respondents, Flordeliza Espiritu-Sarenas and Jimmy O. Espiritu, later came to occupy one-half portion of the property based on an alleged adverse claim dating back to 1966.

In May 2015, while still paying installments, petitioner allowed respondents to till one-half of the property under the condition that they vacate upon his demand.
Dispute arose when petitioner, upon demanding vacation of the portion being tilled, found that respondents refused to leave. They relied on a notice of adverse claim entered in 1966—linked to their late mother, Gertrudes Ducusin—to assert ownership over that portion.
Spouses Salamanca denied ever granting any permission to the respondents and refuted the adverse claim, maintaining that the adverse claim did not translate into an ownership right.

The case commenced with a Complaint for unlawful detainer filed by petitioner in the Municipal Trial Court in Cities (MTCC) on July 25, 2017.
The MTCC rendered a decision on September 25, 2018, ruling in favor of petitioner and ordering the respondents to vacate the premises and pay reasonable monthly rent.
On January 7, 2019, the Regional Trial Court (RTC) upheld the MTCC decision, affirming petitioner’s claim.
The respondents elevated the case to the Court of Appeals (CA) where the CA, in its decision dated September 24, 2020, reversed the lower court rulings, dismissing the complaint for unlawful detainer on the ground of lack of cause of action.
Petitioner then filed a Petition for Review on Certiorari with the Supreme Court, challenging the CA’s reversal and the ruling that the necessary requisites of unlawful detainer were not met.

Petitioner contended that his transfer of possession was merely by tolerance—and not under an agreement that would transfer any proprietary rights—thus, respondents’ continued occupancy was illegal once he demanded vacation.
Respondents argued that their possession of the one-half portion was not by mere tolerance but by color of title, based on the adverse claim entered in 1966. They further contended that petitioner was aware or ought to have been aware of their actual, legal, and uninterrupted possession, bolstered by their payment of real estate taxes.
Additional issues raised involved the validity of third-party transactions (i.e., payments received by an agent without proper authorization) and whether the adverse claim annotation should hold sway over the circumstances presented in an unlawful detainer action.

Petitioner initiated the complaint for unlawful detainer on the basis of a clear demand for vacation of the premises, supported by evidence including a formal letter dated May 23, 2017, which gave a fifteen-day notice to vacate.
notwithstanding the respondents’ claim to ownership via the adverse claim, petitioner maintained that his evidence of continuous, prior possession and the condition under which the respondents were allowed to till the property was sufficient to establish an unlawful detainer case based on mere tolerance.

Whether the CA erred in ruling that petitioner’s complaint for unlawful detainer did not satisfy the jurisdictional requisites by failing to appreciate that the respondents’ possession was derived from petitioner’s tolerance rather than an agreement or color of title.
Whether the existing notice of adverse claim annotated on the property title remains effective and operative until it is cancelled by a judicial order, thereby affecting the respondents’ right to possess.
Whether the evidence demonstrates that the respondents’ possession was merely tolerated by the petitioner and should have ended with his demand to vacate, as opposed to being based on a substantive claim of ownership.