G.R. No. 154203 - Rivera vs. Rivera

The property in dispute is a 228-square meter lot with a two-storey duplex house located in Pasig City.
The duplex originally belonged to spouses Remigio Rivera, Sr. and Consuelo Rivera, who had eleven children.
Among the children were Remigio, Jr. (father of the petitioners) and respondent Virgilio Rivera.

In 1974, upon the migration of the parents to the United States, the spouses allowed Remigio, Jr. and his children (including petitioners Rey Carlo and Gladys Rivera) to occupy one unit of the duplex without rental payment.
In 1985, another son, the respondent, moved into the other unit under similar gratuitous occupancy.
After the death of Remigio, Sr. in 1992, Consuelo Rivera and all eleven children executed an extrajudicial settlement wherein the heirs waived their hereditary rights over four properties—including the lot with the duplex—to Consuelo.

In 1993, Remigio, Jr. and his three sons migrated to the United States, leaving the petitioners as the remaining occupants of the unit.
In 1999, while residing in California, Consuelo sold the duplex house and lot to respondent for ₱500,000.
The sale was executed via a deed of sale through respondent’s daughters, and title was transferred subsequently in respondent’s name.

Following the sale, respondent, represented by his daughter Dolores, offered petitioners a lease contract to occupy the unit from April 30 to June 30, 1999, at a rental of ₱6,000 per month.
Petitioners refused both to sign the lease contract and to vacate the premises, leading respondent to file an unlawful detainer (ejectment) case in the Metropolitan Trial Court (MeTC) for Pasig City.

At the trial court level, respondent’s complaint was based on his registered title and his assertion that petitioners occupied the unit merely by tolerance, under the condition of signing the lease contract.
Petitioners counterclaimed that the deed of sale was fictitious, claiming a right to occupy the premises as co-owners and asserting that they could not be compelled to pay rentals.
The trial court (MeTC) ruled in favor of respondent, ordering petitioners to vacate and pay rentals, attorney’s fees, and costs.
Petitioners appealed the decision to the Regional Trial Court (RTC) arguing:

The RTC reversed the MeTC’s decision, finding that there was no valid lease contract and that petitioners possessed the premises as co-owners.
The Court of Appeals later reversed the RTC’s ruling on March 21, 2002, reinstating the original decision of the MeTC.

Whether petitioners, having been in actual physical possession since 1974, were entitled to remain in possession of the premises until the ownership dispute is judicially resolved.

Whether the ejectment case (Civil Case No. 7529) should have been dismissed on the basis that respondent relied solely on his title, potentially removing the matter from the jurisdiction of the Municipal Trial Court.

Whether respondent held the subject property in trust for the legitimate heirs at the time of filing the ejectment case.

Whether petitioners, by occupying the premises, exercised the right of a co-owner on behalf of their father, Remigio, Jr., despite his physical absence from the property.