G.R. No. 132424 - Spouses Valdez vs. Court of Appeals

Petitioners, Bonifacio R. Valdez, Jr. and Venida M. Valdez, are the registered owners of Lot No. 3 Blk 19 located at Carolina Executive Village, Brgy. Sta. Cruz, Antipolo, Rizal, acquired by virtue of a Sales Contract and evidenced by a Torrens Certificate of Title.
Private respondents, Gabriel and Francisca Fabella, occupied the subject lot by building their house there without a color of title, allegedly depriving the petitioners of rightful possession.

Petitioners filed a complaint for unlawful detainer before the Municipal Trial Court (MTC) of Antipolo, Rizal, alleging that the respondents’ occupation was without legal consent.
The complaint detailed several material facts:

The ownership of the lot by petitioners,
The unlawful entry and occupation by respondents,
Prior communications of demand and the involvement of the Barangay leading to the issuance of a Certification to File Action.

Petitioners incurred substantial lawyer’s fees due to the respondents’ refusal to vacate.

The MTC rendered a decision favorable to petitioners by ordering respondents to vacate the property and to pay rent plus attorney’s fees.
Private respondents appealed the MTC decision to the Regional Trial Court (RTC), which affirmed the MTC ruling in toto on January 8, 1997.
Subsequently, respondents elevated the case to the Court of Appeals (CA), where, on April 22, 1997, the CA reversed the RTC ruling and set aside the earlier decisions.

The CA held that petitioners failed to establish requisite elements for unlawful detainer, notably, the absence of any showing that respondents had occupied with permission (tolerance) or that there was any indicator of prior material possession required in such cases.

Petitioners filed a motion for reconsideration of the CA decision, which was denied on January 30, 1998, prompting the current petition for review under Rule 45.

Petitioners asserted that the unlawful occupation of the lot by respondents constituted a valid ground for an action for unlawful detainer, emphasizing that the remedy for ejectment in cases of mere tolerance is summary in nature.
Respondents contended in their answer that:

The complaint failed to demonstrate that petitioners had prior physical possession or had given any permission for occupancy, and
They had been in open and continuous adverse possession for more than thirty years, as supported by an ocular inspection by the Department of Environment and Natural Resources.

Central to the dispute was the allegation that in unlawful detainer actions, a key jurisdictional requirement is an evidentiary showing of consent or tolerance at the inception of the possession, which, according to respondents, was absent.

Whether the allegations in the complaint clearly established a case for unlawful detainer by sufficiently showing that the petitioners had either given permission for occupancy or that the respondents’ possession had transitioned from lawful to unlawful.
Whether the Municipal Trial Court of Antipolo, Rizal, had original jurisdiction over the complaint filed by petitioners, given the failure to admit the necessary jurisdictional facts such as prior material possession or initial tolerance.