G.R. No. 198270 - Morillo vs. People

The case is a petition for review of a decision by the Court of Appeals (CA) in G.R. No. 211004, August 23, 2017.
Prior proceedings include:

A Decision of the Regional Trial Court (RTC) of Marikina, Branch 272, dated June 15, 2012, dismissing Queen Errika L. Saddi’s ejectment complaint.
A subsequent denial of Saddi’s motion for reconsideration by the RTC in a Resolution dated January 20, 2014.
An intervening decision by the Metropolitan Trial Court (MeTC) of Marikina City, Branch 75 (November 2, 2011) awarding possession and damages against Renomeron.

On July 20, 2010, Saddi purchased a 120-square-meter property located at No. 10 Graphite Street, Twin River Subdivision, Parang, Marikina City from Rosalinda Restar-Ambata.
The property was covered by Transfer Certificate of Title (TCT) No. 009-2010001546 in Saddi’s name and was formerly owned by the late spouses Claro S. Restar and Concepcion T. Restar.
Rosalinda Restar-Ambata, acting as the sole heir (though contested) of the Restars, executed the documents—including an Affidavit of Self-Adjudication and a Deed of Sale—that facilitated the transfer to Saddi.

Before or upon purchase, Saddi became the de facto possessor of the property by virtue of her title.
The transaction was supported by the submission of key documents (title, deed, and affidavit) attached as annexes to the complaint.

On August 4, 2010, while Saddi was in possession as the new owner, Renomeron introduced herself as the adopted daughter of Miguela T. Renomeron (alleged sister of the late Concepcion) and requested accommodation in the property, allegedly by strategy or stealth.
Saddi, out of pity and as a matter of tolerance, allowed Renomeron to stay on the condition that she would vacate by August 8, 2010, as confirmed by an Eviction Letter dated August 4, 2010.

On August 8, 2010, Saddi demanded that Renomeron leave so she could begin renovations, but Renomeron refused to vacate the premises.
As a result, Renomeron was accused of unlawfully detaining the property, having continued her possession beyond the period of permitted occupancy.

Saddi alleged that Renomeron was a mere intruder who, without any valid document or right to stay, prevented her from enjoying her property.
Saddi sought:

Recovery of physical possession of the property.
Payment of reasonable rent (P3,000.00 monthly) for the period of wrongful occupation.
Attorney’s fees, costs, and moral damages.

That she had been in prior possession as a co-owner and heir (by virtue of her familial connection through her mother Miguela).
That the sale, self-adjudication, and subsequent documentation were void or inoperative, as other heirs held interest in the property.
That her occupancy predated or was independent of the alleged “strategy or stealth” and was lawful under her status as an heir.

TCT No. 009-2010001546 evidencing ownership.
The Affidavit of Self-Adjudication and the Deed of Sale executed by Ambata, along with other annexed documents.

Her Certificate of Live Birth establishing her identity as the daughter of Miguela T. Renomeron.
The Death Certificate of Miguela, illustrating her residence at the subject property, thereby supporting her claim of prior possession.

Whether Renomeron’s entry into the property was accomplished through strategy or stealth, rendering her an intruder, or whether her possession was lawfully initiated as a co-owner/heir.
Whether the alleged tolerance (permission) granted by Saddi was sufficient to classify Renomeron’s possession as originally lawful.

Whether Saddi’s complaint properly pleaded an action for unlawful detainer, which requires that the defendant’s possession be initially lawful and later becomes unlawful due to the termination of such permission.
Whether the facts alleged support that the possession was tolerated from the beginning and then converted into an unlawful detention upon the expiration of such tolerance.

Whether the proper remedy in this controversy is ejectment/unlawful detainer or an action for accion publiciana, given the intertwined issues of title and possession.
Whether the challenged documents (e.g., the Eviction Letter) and the sequence of events satisfy the requirements for an unlawful detainer suit.