Case Digest (G.R. No. 175085)
Facts:
Tan Siok Kuan and Pute Ching v. Felicisimo "Boy" Ho, Rodolfo C. Returta, Vicente M. Salas, and Lolita Malonzo, G.R. No. 175085, June 01, 2016, Supreme Court Third Division, Perez, J., writing for the Court.Petitioners Tan Siu Kuan (sometimes spelled Siu) and Pute Ching sued seven occupants — Avelino Bombita, Felix Gagarin, Bernardo Napolitano, Felicisimo "Boy" Ho, Rodolfo Returta (sometimes spelled Retorta), Vicente Salas, and Lolita Malonzo — in seven separate unlawful detainer complaints. Petitioners alleged ownership of the property on Apollo Street, San Francisco del Monte, Quezon City under TCT Nos. 279014 and 279015, that they had leased portions to the occupants since 1972, and that on February 7, 2003 they served demand letters for unpaid rents covering various periods and amounts; the occupants were given ten days to pay or vacate but allegedly failed to do so.
The occupants split into two defense groups. Bombita, Gagarin and Napolitano contended the leases were void ab initio because petitioners are Chinese nationals allegedly ineligible to own land, and that, given long possession since 1968, the proper remedy would be accion publiciana before the RTC. Respondents Ho, Returta, Salas and Malonzo denied any lease relationship, claimed uninterrupted possession since the mid-1960s (having built and occupied the houses), produced letters denying tenancy, and questioned the authenticity or chain of transfer of the TCTs when checked at the Register of Deeds.
The Metropolitan Trial Court (MeTC), Branch 40, Quezon City, in a Joint Decision dated July 8, 2004, ruled for petitioners, finding implied admissions by the defendants and giving greater weight to petitioners' positive proof of title as against respondents' denials; it ordered ejectment, monthly damages, and attorney's fees across the seven consolidated civil cases. The Regional Trial Court (RTC), Branch 87, Quezon City, affirmed the MeTC in a Consolidated Decision dated May 6, 2005. The RTC later issued a Writ of Execution dated January 16, 2006, and the premises were turned over to petitioners on February 24, 2006.
Respondents appealed to the Court of Appeals (CA) on November 18, 2005, challenging, among other things, the MeTC's jurisdiction, application of res inter alios acta, and the RTC's denial of their procedural objections. The CA, however, while confirming MeTC jurisdiction and that the unlawful detainer complaints were timely filed, reversed the RTC in a Decision dated June 29, 2006 (and Resolution October 17, 2006), holding that petitioners had materially failed to prove their lessor status as to respondents and that the admissions of other defendants could not be imputed to respondents under the principle of res inter alios acta; the CA dismissed the unlawful detainer actions for lack of merit.
Petitioners filed a Petition for Revie...(Subscriber-Only)
Issues:
- Was the Regional Trial Court decision of May 6, 2005 final and executory because respondents failed to timely file a Joint Motion for Reconsideration?
- Did petitioners sufficiently prove a lessor‑lessee relationship with respondents to warrant ejectment in an unlawf...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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