G.R. No. 141418 - Leonin vs. Court of Appeals

Prospero Leonin and five others were co-owners of a 400-square meter property located at KJ Street, East Kamias, Quezon City.
The property comprised a two-storey house and a three-door apartment identified as No. 1-A, B, and C.

The petitioners, who are the siblings of Prospero, were allowed by the owners to occupy Apartment C without any rental payment, their occupancy being by mere tolerance.
The owners subsequently mortgaged the property with the Government Service Insurance System (GSIS) to secure a loan of P48,000.00.
The failure to settle the loan led GSIS to foreclose the mortgage and sell the property at public auction.

Prospero’s brother, Teofilo Leonin, redeemed the foreclosed property from GSIS.
GSIS executed a Release of Mortgage and turned over the owner’s duplicate title to Teofilo.
Teofilo later sold the property by Deed of Absolute Sale to his daughter, Germaine Leonin (the respondent), for P48,000.00.
Subsequent to the sale, Germaine was issued a new title, Transfer Certificate of Title (TCT) No. 95939.

After the death of Teofilo, respondent sent a letter to her father’s siblings (the petitioners), asking them to vacate Apartment C as their occupation was by mere tolerance and urging them to execute a lease contract.
The petitioners did not comply with the letter’s demand.
Respondent sent a second letter on October 24, 1996, demanding that the petitioners vacate within 30 days, warning that failure to do so would prompt an unlawful detainer action.

On February 25, 1997, respondent filed a complaint for unlawful detainer before the Metropolitan Trial Court (MeTC) of Quezon City.
Concurrently, Prospero and co-owners initiated an annulment case against respondent at the Regional Trial Court (RTC) of Quezon City, alleging that the deed of sale was simulated and involved a false consideration.
The RTC, in a decision rendered on November 19, 1997, nullified the deed of absolute sale and ordered respondent to deliver possession of the property to the co-owners.
Despite the annulment case, respondent pursued the unlawful detainer action, which eventually resulted in a favorable decision at the MeTC.

The MeTC rendered its Decision on February 20, 1998, in favor of respondent, ordering the petitioners to vacate the premises and requiring them to pay attorney’s fees and costs.
The Quezon City RTC affirmed the MeTC decision.
The petitioners raised issues on appeal regarding jurisdiction, the timeliness of the complaint, and the validity and effect of the deed of sale and title issuance.
The Court of Appeals affirmed the lower court rulings, holding that the complaint was timely (filed within one year from the latest demand of October 24, 1996), that unlawful detainer jurisdiction was appropriate, and that respondent’s acquisition of title conferred the right to possession.

Whether the Metropolitan Trial Court (MeTC) had jurisdiction to hear and decide the unlawful detainer case despite petitioners’ contention that there was no forcible entry nor any act qualifying under Section 1, Rule 70 of the 1997 Rules of Civil Procedure.
Whether the one-year period for filing the complaint was properly computed from the date of respondent’s last demand to vacate.

Whether respondent acquired the right to possess the property upon the execution of the Deed of Absolute Sale and the issuance of Transfer Certificate of Title No. 95939 in her favor.
Whether the petitioners’ occupancy, being by mere tolerance and thus de facto, could override the registered title and sale executed by Teofilo.

Whether the pendency of the annulment case concerning the deed of sale affected or abated the jurisdiction of the court over the unlawful detainer proceeding initiated by respondent.