Case Digest (G.R. No. 237720) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves a legal dispute between Alvin F. Samonte (Petitioner) and Demetria N. Domingo, who is married to Daniel SB. Domingo (Respondent). The matter originated from a Complaint for Unlawful Detainer filed by Domingo against Samonte before the Metropolitan Trial Court (MeTC) of Manila, under Civil Case No. 188910-CV. Domingo claimed to have purchased a residential property located on New Antipolo Street, District of Tondo II-B, Manila, with an area of 58.5 square meters. She asserted that the sale was formalized through a Deed of Sale executed on July 8, 2011. Despite multiple demands for him to vacate the property, Samonte allegedly continued to occupy it and rented parts of it to tenants. In his Answer, Samonte denied the sale, contending that he had only borrowed ₱59,000 from Domingo and that he had inadvertently signed a document he believed to be a mortgage contract.The trial court's MeTC issued a ruling on May 15, 2013, dismissing Domingo’s complaint, citin
... Case Digest (G.R. No. 237720) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Initiation of the Dispute
- The property in issue is a residential house made of light materials, measuring 58.5 square meters, located on New Antipolo Street, District of Tondo II-B, Manila.
- Parties Involved:
- Demetria N. Domingo – asserted as having purchased the property.
- Alvin F. Samonte – disputed the alleged sale and maintained possession.
- Documentary Basis and Claims:
- Domingo filed a Complaint for Unlawful Detainer based on a Deed of Sale of Residential House executed on July 8, 2011, alleging she bought the subject property from Samonte.
- Samonte, in his Answer, denied any sale and averred that the executed document was in fact intended to be a contract of mortgage pertaining to a loan he received from Domingo amounting to P59,000.00, alleging he was defrauded and taken advantage of.
- Procedural History in the Lower Courts:
- The Metropolitan Trial Court (MeTC) of Manila, Branch 3, dismissed Domingo’s complaint due to her failure to prove the existence of a contract of lease and the proper transmission of a demand to vacate.
- The Regional Trial Court (RTC) of Manila, Branch 24, reversed the MeTC ruling, holding that:
- An action for unlawful detainer could be instituted by persons other than the lessor if the right to possession had been terminated by any contract.
- An allegation that a demand to vacate was sent to Samonte satisfied the jurisdictional requirement.
- Samonte’s motion for reconsideration before RTC Branch 24 was denied.
- Parallel Proceedings on the Validity of the Deed
- Samonte initiated a separate case for annulment of the deed of sale and for damages (Civil Case No. 12-128721) with the RTC of Manila, Branch 32.
- The RTC Branch 32 ruled that the transaction was merely an equitable mortgage to secure Samonte’s debt to Domingo and declared the Deed of Sale null and void.
- This decision was affirmed by the Court of Appeals (CA) in CA-G.R. CV No. 107254, becoming final and executory on September 15, 2017.
- Developments in the Court of Appeals in the Unlawful Detainer Action
- The CA, in its decision dated August 17, 2017 in CA-G.R. SP No. 144022, affirmed the RTC Branch 24 ruling that ordered Samonte and all persons claiming under him to vacate the subject property, thus granting Domingo the right of possession.
- During the pendency of the CA proceedings, Samonte filed a motion for reconsideration alleging that the separate annulment ruling (declaring the deed null and void) was a supervening event.
- The CA, in a resolution dated February 13, 2018, denied Samonte’s motion for reconsideration.
- Samonte then filed a Petition for Review on Certiorari with the Supreme Court, raising the issue of whether Domingo’s possession right, based on the nullified deed, could still be upheld.
Issues:
- Whether Domingo has the right to possess the subject property, considering that the Deed of Sale upon which her claim was based was declared null and void in a separate case.
- Whether the principle of res judicata, arising from the final and executory judgment on the deed’s nullity, prevents the re-litigation of the deed’s validity in the context of the unlawful detainer action.
- Whether the provisional ruling on possession by the subordinate courts should be sustained when weighed against the conclusiveness of the previous judgments affecting the deed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)