Case Digest (G.R. No. 147812)
Facts:
- The case involves Leonardo R. Ocampo (petitioner) and Leonora Tirona (respondent).
- The dispute is over a parcel of land on Alvarez Street, Pasay City, claimed by Ocampo based on Transfer Certificate of Title (TCT) No. 134359.
- Ocampo purchased the land from Rosauro Breton, the heir of the original owner, Alipio Breton Cruz.
- Although the TCT was not yet in Ocampo's name, he asserted possession and management of the property.
- Tirona was a lessee occupying a portion of the land.
- The Metropolitan Trial Court (MTC) found that Ocampo notified Tirona of his ownership on March 9, 1995, and she initially paid rent.
- On July 5, 1995, Tirona's legal counsel informed Ocampo she would stop paying rent, claiming a right of first refusal under the Urban Land Reform Act.
- Ocampo demanded payment of arrears and vacating the premises, but Tirona refused.
- Ocampo filed a complaint for unlawful detainer and damages on September 11, 1995.
- Tirona countered, claiming the true owner was Doña Lourdes Rodriguez Yaneza and asserting her right to occupy the property.
- The MTC ruled in favor of Ocampo, ordering Tirona to vacate and pay arrears.
- Tirona appealed to the Regional Trial Court (RTC), which affirmed the MTC's decision.
- The Court of Appeals later set aside the RTC's ruling, prompting Ocampo to file a petition for review.
Issue:
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Ruling:
- The Supreme Court ruled that the Court of Appeals erred regarding Ocampo's right to eject Tirona.
- The appellate court's consideration of ownership as a primary issue in the unlawful detainer case was incorrect.
- The Supreme Court rei...(Unlock)
Ratio:
- The Supreme Court emphasized that unlawful detainer cases are summary proceedings focused on lease facts and the expiration or violation of its terms.
- Ocampo properly notified Tirona of his ownership, and her continued occupancy indicated acceptance of the lease terms.
- Tirona's refusal to pay rent constituted a violation of the lease agreement, justifying Ocampo's action for unlawful detainer.
- The Court clarified that ownership is not essential in u...continue reading
Case Digest (G.R. No. 147812)
Facts:
The case involves Leonardo R. Ocampo as the petitioner and Leonora Tirona as the respondent. The dispute centers around a parcel of land located at Alvarez Street, Pasay City, which Ocampo claims to own based on Transfer Certificate of Title (TCT) No. 134359. Ocampo purchased the land from Rosauro Breton, the heir of the original owner, Alipio Breton Cruz. Although the TCT was not yet in Ocampo's name, he asserted that he had possession and management of the property. Tirona, on the other hand, was a lessee occupying a portion of the land.
The Metropolitan Trial Court (MTC) found that Ocampo had formally notified Tirona of his ownership on March 9, 1995, and that she had initially paid rent. However, on July 5, 1995, Tirona's legal counsel informed Ocampo that she would stop paying rent due to her claim of a right of first refusal under the Urban Land Reform Act, pending processing by the National Housing Authority. Ocampo subsequently demanded payment of arrears and vacating the premises, but Tirona refused.
Ocampo filed a complaint for unlawful detainer and damages against Tirona on September 11, 1995. Tirona countered by claiming that the true owner of the land was DoAa Lourdes Rodriguez Yaneza and that she had a right to occupy the property. The MTC ruled in favor of Ocampo, ordering Tirona to vacate the premises and pay arrears. Tirona appealed to the Regional Trial Court (RTC), which affirmed the MTC's decision...