G.R. No. 239727 - Spouses Belvis vs. Spouses Erola

The case is a petition for review on certiorari by Spouses Julian Belvis, Sr. and Cecilia Belvis, along with their children, against Spouses Conrado V. Erola and Marilyn Erola, represented by Maureen Frias.
The dispute involves a 29,772 square meter lot in Barangay Malag-it, Pontevedra, Capiz, covered by Transfer Certificate of Title No. T-26108, registered in Conrado Erola's name.
Conrado allegedly purchased the property in October 1978.
The petitioners, relatives of the respondents, claimed they were allowed to occupy the lot with the understanding they would vacate upon demand.
On July 2, 2012, the respondents demanded the petitioners vacate within 30 days, which the petitioners ignored.
After failed barangay conciliation, the respondents filed a complaint for unlawful detainer and damages.
The Municipal Circuit Trial Court (MCTC) ruled in favor of the respondents, ordering the petitioners to vacate and pay rentals and attorney's fees.
The Regional Trial Court (RTC) and the Court of Appeals (CA) upheld the MCTC's decision.
The petitioners argued they had possessed the property for over 34 years, believing they were co-owners, and claimed the respondents did not appear during barangay proceedings.

The Supreme Court ruled that the petition is partly meritorious.
The Court found that the respondents substantially complied with the mandatory barangay conciliation proceedings.
The petitioners were not deemed builders in good faith under Article 448, as their possession was by mere tolerance, not ownership.
The case was...(Unlock)

The Court noted that although the respondents did not personally appear during the barangay conciliation, they were represented by Maureen Frias, and the proceedings followed legal requirements.
The purpose of barangay conciliation is to facilitate amicable settlements, which was achieved despite the absence of personal appearances.
The petitioners' claim of being builders in good faith was rejected,...continue reading