G.R. No. 196529 - Go vs. Looyuko

William T. Go (petitioner) and Alberto T. Looyuko (respondent) were involved in a business partnership under the Noahas Ark Group of Companies.
Their partnership was governed by a written agreement dated February 9, 1982, outlining the rights and obligations of the partners.
Jimmy Go, brother of William, was also a partner in the business, further complicating the relationships and claims over business assets.

As part of the agreed arrangement, William, who was appointed Chief of Staff of Noahas Ark Sugar Refinery, was allowed by Looyuko to occupy a townhouse located in Gilmore Townhomes, Granada Street, Quezon City.
In 1986, a subsequent agreement between Looyuko and Jimmy Go furthered the terms of their business partnership, hinting at a more complex relationship concerning property rights.
On October 28, 1998, Looyuko demanded that William vacate the townhouse, which subsequently led to Jimmy filing an adverse claim over the property by annotating his interest on the title, asserting that the townhouse was purchased with partnership funds.

William refused to vacate the property, relying on the strength of the adverse claim made by Jimmy as part of his privilege connected to his position in Noahas Ark.
On December 2, 1998, Looyuko filed a complaint for unlawful detainer before the Metropolitan Trial Court (MeTC), Branch 35, Quezon City, alleging that William’s occupation was merely tolerated on the condition that he would vacate upon demand.
In support, Looyuko presented the Transfer Certificate of Title (TCT) No. 108763 along with his demand letter, asserting his right as the registered owner.

William countered with evidence including the partnership agreements, a contract to sell the property to Noahas Ark, and a cash voucher evidencing payment for its acquisition.
The evidence aimed to establish that the property was, in substance, a partnership asset and that his occupation was justified as part of his benefits as Chief of Staff.

On May 20, 2000, the MeTC rendered a decision in favor of Looyuko, recognizing him as the registered owner with the right to possess the townhouse.
William subsequently appealed to the Quezon City Regional Trial Court (QC RTC), while Looyuko moved for execution pending appeal due to allegedly insufficient supersedeas bond.
The QC RTC initially deferred proceedings upon recognizing that a related civil case for specific performance against Looyuko (filed by Jimmy before the Pasig RTC) could impact the ownership claim.
Despite the QC RTC’s temporary holding, on March 29, 2004, the QC RTC ultimately reversed the MeTC’s findings, ruling in favor of William by giving weight to the partnership agreements and an affidavit by Jimmy that supported William’s authority to occupy the property.

The CA, in its October 29, 2009 Decision, reversed the QC RTC ruling by emphasizing that the issue of possession in an unlawful detainer case must be resolved on the basis of physical possession regardless of underlying ownership disputes.
The CA held that Looyuko’s TCT, as evidence of his registered ownership, entitled him to possession and that any challenge to the title should be addressed in a direct proceeding rather than in an ejectment action.
Following William’s motion for reconsideration—which was denied in the March 30, 2011 Resolution—the petition for review on certiorari was filed under Rule 45, bringing the matters before the Supreme Court for resolution.

Whether the petition for review under Rule 45 should be limited strictly to questions of law without reexamination of factual evidence.
Whether William’s attempt to have the Court evaluate issues of fact, particularly regarding the strength of his partnership evidence, falls outside the ambit of review.

Whether the factual dispute regarding ownership—highlighted by the partnership agreements and adverse claim—should affect the resolution of the unlawful detainer action, which primarily focuses on physical possession.
Whether the issue of ownership, though raised by William, can be resolved adequately without encroaching upon the matter of possession.

Whether the documentary evidence, including Looyuko’s Transfer Certificate of Title, should be determinative in granting possession to the registered owner.
Whether the additional evidence presented by William (namely, the partnership agreements and the contract to sell) is enough to offset the presumptively superior right conferred by a Torrens title.