G.R. No. 193075 - Reyes, Sr. vs. Heirs of Forlales

The case involves petitioners Emmanuel Reyes, Sr. and Mutya M. Reyes versus the Heirs of Deogracias Forlales, comprising various respondents including Napoleon Forlales, Lita Helen Forlales-Fradejas, Jaime Forlales, Jr., among others.
The controversy arose from the petitioners’ occupation of a disputed portion of land, allegedly part of Lot No. 1408 in Barangay Dapawan, Odiongan, Province of Romblon.

The dispute originated with an unlawful detainer suit filed on October 27, 2005 by the respondents demanding that the petitioners vacate the portion of land.
The disputed land formed part of the estate of Deogracias Forlales, initially adjudicated to Mercedes Forlales Bautista.
As early as 1978, petitioners claimed they had been occupying the disputed portion, and in 1988 they executed an affidavit asserting that their stay was with the permission of Independencia Forlales Fetalvero, the estate administrator.

On January 5, 1989, Mercedes Forlales Bautista invited the petitioners for a formal discussion regarding their temporary possession; the petitioners declined by sending a note requesting an extension “for the sake of convenience” of their family.
On May 28, 1993, after prolonged occupation, Independencia Forlales Fetalvero sent a letter to petitioners demanding vacating within six (6) months.
Despite the demand in 1993, no immediate legal action was undertaken until respondents initiated a complaint for unlawful detainer on August 28, 1997, which was eventually dismissed on September 29, 1997 for being filed beyond the one-year period required.

On May 16, 2005, respondents, acting through Independencia, filed an ejectment and demolition complaint before the Office of the Sangguniang Barangay, followed by a subsequent formal letter dated May 27, 2005 demanding vacating and cessation of construction.
The unresolved barangay complaint prompted the filing of an ejectment suit on October 27, 2005 before the Municipal Circuit Trial Court (MCTC), where the petitioners’ continued occupation and alleged improvements on the land were challenged.
Early evidences from the petitioners included an affidavit and a note which, paradoxically, acknowledged that their occupation was by permission (or mere tolerance) of the respondents.
The petitioners, in their defense, also claimed the land belonged originally to different owners (Alejandra Forlales Fabella and Linda Fontamillas) and contended that the respondents’ ejectment suit was moot on grounds of prescription and res judicata.

The MCTC in its July 20, 2007 decision found that the petitioners occupied the lot owned by the respondents and dismissed their claim of ownership based on their own affidavit and note.
The MCTC held that the petitioners’ occupation, which had continued since 1993, was by mere tolerance until the respondents rescinded such tolerance via formal demand, thereby rendering the possession illegal post-demand.
Following appeals, both the Regional Trial Court (RTC) and the Court of Appeals (CA) affirmed the lower courts’ findings regarding the nature of the petitioners’ possession and the timing of the demands to vacate.

Petitioners raised issues regarding the proper computation of the one-year limitation period for unlawful detainer actions, arguing it should commence from their first demand (May 28, 1993) and not from the final demand on May 27, 2005.
They questioned the characterization of the suit as wrongful or as one predicated on unlawful detainer versus forcible entry, arguing that the respondents never truly tolerated their occupation.
Additionally, petitioners invoked the doctrine of res judicata, contending that a previous dismissal, which was on the merits due to prescription, barred the current suit.

Is the one-year period to file an unlawful detainer suit to be computed from the first formal demand to vacate (May 28, 1993) or from the last demand (May 27, 2005) by the respondents?
Does the filing of a subsequent ejectment suit after a preceding dismissal amount to resetting the prescription period?

Was the petitioners’ initial possession of the disputed land by mere tolerance authorized by the respondents?
If the occupancy started as tolerated, at what point did it become illegal, and does this affect the remedy (forcible entry versus unlawful detainer)?

Should the respondents’ action be properly characterized as an ejectment suit for unlawful detainer or as a case of forcible entry, thereby affecting the applicable prescriptive period?
Were the allegations in the complaint sufficient to establish a case of unlawful detainer under the requirements of Rule 70 of the Rules of Court?

Does the dismissal of the earlier unlawful detainer suit on the merits invoke res judicata, thereby barring a subsequent suit on identical claims?
Has the previous decision conclusively determined the issues regarding the validity of the petitioners’ occupation?