Case Digest (G.R. No. 154391-92)
Facts:
In Spouses Ismael and Teresita Macasaet vs. Spouses Vicente and Rosario Macasaet (G.R. Nos. 154391-92, September 30, 2004), petitioners Ismael and Teresita Macasaet, a married couple, are the son and daughter-in-law of respondents Vicente and Rosario Macasaet. In March 1992, respondents invited petitioners to occupy two titled lots (TCT T-78521 and TCT T-103141) in Banay-banay, Lipa City, to foster family unity. Petitioners built a residence and housed their construction business on these lots in good faith and with parental consent. In August 1997, an unresolved family conflict led respondents to demand vacation. When petitioners refused, respondents filed an ejectment suit in the MTCC of Lipa City in December 1997, alleging a verbal lease and unpaid weekly rent of ₱500. Petitioners denied any lease, claiming gratuitous occupation and that one lot was an advance inheritance and the other a dation in payment. The MTCC ruled occupancy was by mere tolerance and ordered ejectment.Case Digest (G.R. No. 154391-92)
Facts:
- Parties and Subject Matter
- Petitioners: Spouses Ismael and Teresita Macasaet (son and daughter-in-law)
- Respondents: Spouses Vicente and Rosario Macasaet (parents)
- Property: Two parcels in Banay-banay, Lipa City (TCT Nos. T-78521 & T-103141)
- Background and Proceedings
- March 1992: Respondents invite petitioners to occupy lots for residence and construction business—allegedly as advance inheritance and/or payment for materials.
- Conflict and Demand: June 6, 1996 demand letter; October 14, 1997 barangay conciliation; December 10, 1997 MTCC ejectment suit filed alleging a verbal lease and nonpayment of P 500/week rent.
- Lower Courts’ Decisions:
- MTCC (1998): Held occupation by mere tolerance; ordered ejectment; dismissed inheritance/allotment and dation-in-payment claims.
- RTC (1999): Affirmed ejectment; allowed respondents to appropriate improvements after indemnity under Civil Code Art. 448.
- CA (2002): Affirmed ejectment on tolerance theory; held Art. 448 inapplicable and applied lease rule (Art. 1678) awarding petitioners half the value of improvements (P 475,000); deleted attorney’s fees; remanded for respondents’ option and implementation.
Issues:
- Ejectment and Procedure
- Whether respondents stated a proper cause of action and whether Rule 70, Sec. 17 (on judgment) applied; grounds for dismissal; award of damages/attorney’s fees.
- Whether personal appearance at the preliminary conference was mandatory or may be by a representative under Rule 18.
- Improvements and Indemnity
- Whether petitioners’ right to reimbursement for improvements is governed by Civil Code Art. 1678 (lease), Arts. 447/453/454, or Art. 448 (accession in good faith).
- How to compute and award reimbursements: half-value rule vs indemnity and respondents’ option to appropriate, compel purchase, or fix rent.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)