G.R. No. 193719 - Pacasum, Sr. vs. Zamoranos

Case Digest (G.R. No. 193719)
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Facts:

Background of the Property and Acquisition

The subject matter is a 635.50 square meter parcel of land located at Calle Solana, Intramuros, Manila.
The property is registered under Transfer Certificate of Title (TCT) No. 87556 in the name of SLTEAS Phoenix Solutions, Inc.
Respondent acquired the property through a Deed of Assignment dated 4 June 1999 executed by the Spouses Ong Tiko and Emerenciana Sylianteng.

Occupancy and Subsequent Developments

Due to important business concerns, the respondent left the property idle and unguarded for a period after acquisition.
In October 2003, an ocular inspection revealed that petitioner Hubert NuAez along with 21 other individuals were in occupation of the parcel.

Initiation of the Forcible Entry Case by Respondent

Respondent initially filed a complaint for forcible entry on 5 December 2003 before Branch 4 of the Metropolitan Trial Court (MeTC) of Manila, targeting one individual initially and later impleading petitioner and other occupants.
The complaint alleged that:

Respondent, through its representatives and predecessors-in-interest, continuously possessed the property and exercised all attributes of ownership (including payment of real property taxes and other expenses).
Petitioners and other co-defendants occupied the parcel unlawfully by means of strategy and stealth since 1999.

Respondent’s prayer included:

Ejectment of all occupants from the property.
Payment of reasonable rentals, attorney’s fees, litigation expenses, and costs.

Petitioner’s Response and Defense

In his Answer filed on 14 February 2004, petitioner specifically denied the material allegations of respondent’s amended complaint.
Petitioner asserted that the property was actually leased to him by Maria Ysabel Potenciano Padilla Sylianteng through a subsisting lease agreement.
He argued that the Metropolitan Trial Court lacked jurisdiction due to:

The absence of a prior demand to vacate.
The failure to refer the matter to the barangay authorities for an amicable settlement.

The other defendants, also questioning the jurisdiction of the MeTC, filed a Motion to Dismiss.

Evidentiary Proceedings and Survey Issues

An ocular inspection on 9 June 2004 by the MeTC noted crowding of residential units, rendering the determination of metes and bounds of the property difficult.
Despite petitioner’s inability to present his lessor’s title, he agreed to determine the property’s measurement based on TCT No. 87556.
The parties failed to secure a survey from an impartial surveyor from the Office of the City Assessor or the City Engineer.
Consequently, respondent submitted a survey plan prepared by Geodetic Engineer Joseph Padilla, which indicated that petitioner was occupying a portion of the subject parcel.

Decisions of the Lower Courts

The MeTC rendered a Decision on 23 November 2004 ruling in favor of respondent, ordering:

Ejectment of petitioner and all co-defendants from the premises.
Payment by each defendant of Php5,000.00 per month from October 2003 until the premises were vacated.
Payment of Php15,000.00 as attorney’s fees and other litigation costs.

The Regional Trial Court (RTC) of Manila, in Civil Case No. 05-112490, affirmed this decision on 14 July 2005 in toto.

Elevation to the Court of Appeals and Grounds of the Petition

Dissatisfied with the RTC’s affirmation, petitioner elevated the case to the Court of Appeals through a petition for review filed pursuant to Section 1, Rule 42 of the 1997 Rules of Civil Procedure.
Petitioner’s petition raised two main grounds:

That the MeTC lacked jurisdiction to try the case as the elements of forcible entry were not present and there was a question of ownership.
That petitioner should not vacate the premises given an existing lease contract with the owner, which he argued violated Article 1671 of the Civil Code.

Additional Relevant Developments

Petitioner attempted to rely on a demand letter dated 31 July 1996 purportedly sent by respondent’s counsel; however, its admission and evidentiary value were challenged.
The record revealed that both parties, despite agreeing to an impartial survey, failed to secure one from the proper government offices, leading to reliance on respondent’s survey plan.
The procedural posture also involved motions for reconsideration and related evidentiary submissions prior to the Court of Appeals’ resolution.

Issues:

Jurisdiction of the MeTC

Whether the Metropolitan Trial Court had proper original and exclusive jurisdiction over the ejectment (forcible entry) case based on the allegations and relief sought.
Whether the requisite elements of forcible entry – prior possession, deprivation by force/intimidation/strategy or stealth, and the one-year prescriptive period – were properly alleged.

Validity and Impact of the Lease Agreement

Whether petitioner’s assertion of a subsisting lease agreement with Maria Ysabel Potenciano Padilla Sylianteng negated respondent’s claim of continuous possession and ownership.
Whether the existence of such a lease could affect the jurisdiction or the merits of the ejectment action.

Evidentiary and Procedural Matters

Whether the survey plan prepared by Geodetic Engineer Joseph Padilla sufficiently established petitioner’s encroachment on respondent’s property.
Whether petitioner’s reliance on the demand letter dated 31 July 1996, as well as other arguments, could be raised at this stage to challenge the lower court’s findings and jurisdiction.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. 193719)
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