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 a...

Facts:

Ownership and Lease Agreement

• Petitioner Leonardo R. Ocampo claimed ownership of a parcel of land located at Alvarez Street, Pasay City, covered by Transfer Certificate of Title (TCT) No. 134359. He purchased the land from Rosauro Breton, an heir of the registered owner, Alipio Breton Cruz.
• Respondent Leonora Tirona was a lessee occupying a portion of the subject land. Ocampo notified Tirona of his ownership through a letter dated 1 March 1995, which Tirona acknowledged by paying some monthly rentals.

Non-Payment of Rentals

• On 5 July 1995, Tirona, through her counsel, informed Ocampo that she would temporarily stop paying rent, invoking her right of first refusal under Presidential Decree (PD) No. 1517, as the land was declared an area for priority development.
• Ocampo demanded payment of arrears and for Tirona to vacate the premises in a letter dated 7 August 1995. Tirona refused to comply, leading Ocampo to file an unlawful detainer case before the Metropolitan Trial Court (MTC).

Tirona’s Defense

• Tirona initially claimed that the land was owned by Doña Lourdes Rodriguez Yaneza. Later, she amended her answer, asserting that Maria Lourdes Breton-Mendiola, another heir of Alipio Breton, was the true owner. She argued that Ocampo could not acquire title from Rosauro Breton due to waivers executed in favor of Maria Lourdes.

Procedural History

• The MTC ruled in favor of Ocampo, ordering Tirona to vacate the property and pay unpaid rentals, attorney’s fees, and costs. The Regional Trial Court (RTC) affirmed the MTC’s decision.
• The Court of Appeals (CA) reversed the lower courts, ruling that Ocampo could not eject Tirona until the partition of Alipio Breton’s estate was finalized.

Issue:

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Ruling:

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Ratio:

1. Unlawful Detainer is Summary: Unlawful detainer cases are summary proceedings that focus on possession, not ownership. The fact of lease and its violation are the only elements to be proved.
2. Ownership Must Be Raised in Proper Action: Claims of ownership cannot be resolved in an unlawful detainer case. Such claims must be addressed in a separate action, as a certificate of title cannot be collaterally attacked.
3. Interpleader as a Remedy: A lessee facing conflicting claims over property should file an interpleader action to protect themselves from double liability. Tirona’s failure to do so undermined her defense.
4. Legal Interest on Unpaid Rentals: Unpaid rentals accrue legal interest from the date of demand, with the rate increasing to 12% upon finality of the decision.