Title
Gayoso vs. Twenty-Two Realty Development Corp.
Case
G.R. No. 147874
Decision Date
Jul 17, 2006
Dispute over possession of a Mandaluyong lot; petitioners claimed void sale, but SC upheld MeTC jurisdiction, ruling possession, not ownership, was primary issue.

Case Digest (G.R. No. 147874)

Facts:

Dolores Gayoso, Danny Gayoso, Elizabeth G. Dondriano, Victoriano Gayoso, Christopher Gayoso, Remedios Gayoso and the Heirs of Victoriano Gayoso v. Twenty-Two Realty Development Corporation, G.R. No. 147874, July 17, 2006, Supreme Court Second Division, Sandoval‑Gutierrez, J., writing for the Court.

The dispute began with a 1954 private sale: on October 11, 1954, Victoriano Gayoso sold a lot on Mariveles corner Calbayog Streets, Mandaluyong City, to Prospero Almeda. After the sale, Almeda permitted Gayoso and his children (the present petitioners) to remain on the lot as lessees at P20.00 per month. At some later point Almeda’s heirs sold the property to Twenty‑Two Realty Development Corporation (TTRDC), and title was transferred to TTRDC on February 19, 1996.

Allegedly having stopped paying rent, the petitioners received letters dated September 12 and October 17, 1996 from TTRDC demanding vacatur; they refused. On December 12, 1996 TTRDC filed a complaint for unlawful detainer (ejectment) in the Metropolitan Trial Court (MeTC), Branch 60, Mandaluyong City, docketed as Civil Case No. 15340, seeking possession and unpaid rentals.

In their answer the petitioners raised ownership: they alleged that Victoriano Gayoso (a married man) had sold conjugal property without his wife’s consent, rendering the sale void, and thus argued the MeTC lacked jurisdiction because title was being questioned. On July 21, 1997 the MeTC rendered judgment ordering the defendants to vacate, awarding P4,000.00 for unpaid rentals (February 1981–December 1996), P20.00 per month thereafter until vacatur, P10,000.00 attorney’s fees, and costs, and dismissing the counterclaim.

The Regional Trial Court (RTC), Branch 213, Mandaluyong City, affirmed the MeTC, finding the elements of unlawful detainer present and upholding the Metropolitian Trial Court’s jurisdiction. The petitioners then sought relief with the Court of Appeals by a Petition for Review under Rule 42. In a Decision dated April 20, 2001 in CA‑G.R. SP No. 48001 the Court of Appeals affirmed the RTC “in toto.”

(Subscriber-Only)

Issues:

  • Did the Metropolitan Trial Court have jurisdiction to hear and decide the unlawful detainer action despite the petitioners’ affirmative pleading raising ownership of the disputed ...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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