G.R. No. 217111 - Alfiler vs. Spouses Cayabyab

Case Summary (G.R. No. 217111)

Factual Background

The subject property was a parcel at No. 186 Pajo Street, Barangay Quirino 2‑C, Quezon City, of 266.9 square meters, registered as Transfer Certificate of Title No. RT‑115646 (324155) in the name of Quintin Santiago, Jr., married to Violeta E. Santiago. In March 1985 Quintin filed a complaint for ejectment and squatting before the Lupon Tagapamayapa against petitioner’s mother and others, and on May 1, 1985 the parties executed an Amicable Settlement providing for the sale of the lot at P550.00 per square meter and installment payments. The alleged buyers made partial payments totaling P72,425.00, the last in June 1986. Quintin died on March 12, 1997. On August 20, 1997 a Deed of Absolute Sale (DOAS) purportedly executed by Quintin through an attorney‑in‑fact, Norman Santiago, conveyed the lot to Sps. John and Geraldine Cayabyab, who later filed the ejectment complaint.

Complaint and Claims in the MeTC

On March 18, 2010 Sps. Cayabyab sued petitioner and others in the MeTC for ejectment, alleging ownership under the DOAS dated August 20, 1997 and asserting that the defendants had illegally remained in possession since 1997 despite a final demand dated May 8, 2009. In their Answer and Position Paper, petitioner and co‑defendants denied the respondents’ ownership, contended that no Special Power of Attorney (SPA) authorized Norman to sell the property, argued that any SPA was extinguished by Quintin’s death on March 12, 1997, asserted that the Amicable Settlement embodied a consummated contract of sale in favor of their predecessors‑in‑interest, and challenged the MeTC’s jurisdiction on the ground that the proper remedy was accion publiciana before the RTC.

MeTC Decision

The MeTC rendered judgment for Sps. Cayabyab on January 3, 2011, ordering petitioner and the other defendants to vacate the premises, to pay monthly damages from May 8, 2009, and awarding attorney’s fees and costs. The MeTC found that the defendants failed to prove a better right to possession and concluded that respondents proved ownership by a preponderance of evidence, but its decision contained only summary statements of conclusion without substantive discussion of the probative value of evidence or a detailed legal analysis of the validity of the DOAS or the alleged SPA.

RTC Proceedings and Decision

Petitioner and another defendant appealed the MeTC judgment to the RTC under Rule 40. The RTC, in its January 9, 2013 Decision, affirmed the MeTC judgment in toto, ordered issuance of the writ of execution, and denied petitioner’s Motion for Reconsideration by Order dated October 17, 2013. The RTC repeated the MeTC’s conclusions and provided a brief statement on the nature of forcible entry and unlawful detainer but did not engage in a detailed examination of the DOAS, the existence or sufficiency of any SPA, or the legal effect of Quintin’s death on the alleged agency and sale.

Court of Appeals Proceedings and Resolutions

Petitioner filed a Petition for Certiorari under Rule 65 with the Court of Appeals on November 22, 2013, challenging the RTC decision. The CA dismissed the petition by Resolution dated December 13, 2013 on the ground that petitioner had adopted the wrong mode of appeal because the RTC acted in its appellate capacity and the proper remedy was a petition for review under Rule 42, which had to be filed within fifteen days. The CA denied petitioner’s motion for reconsideration in its February 17, 2015 Resolution, rejecting petitioner’s plea for liberal construction and concluding that her claims amounted to errors of judgment proper to appeal, not jurisdictional errors cognizable in certiorari.

Issues Presented to the Supreme Court

In the petition for review under Rule 45, petitioner raised whether the CA erred in dismissing her Rule 65 petition as the wrong mode of appeal notwithstanding compelling reasons to apply liberal construction to secure substantial justice, and whether the CA should have given due course to the petition to allow resolution on the merits because the lower courts committed patent errors and abuse of discretion in adjudicating ownership and possession.

Parties’ Contentions Before the Supreme Court

Petitioner argued that the DOAS was null and void because it was executed after Quintin’s death and lacked the SPA that respondents claimed to have attached; that any SPA would have been extinguished by Quintin’s death; and that the MeTC lacked jurisdiction because respondents’ cause of action fell under accion publiciana and the complaint was filed beyond one year from alleged dispossession. Sps. Cayabyab maintained that the CA correctly dismissed the certiorari petition and that the MeTC and RTC properly found their ownership and right to possession; they further asserted that petitioner’s continued occupation without paying rent supported their claim.

Supreme Court’s Procedural Analysis

The Supreme Court agreed that petitioner invoked the wrong remedy by filing a Rule 65 certiorari petition before the CA instead of a petition for review under Rule 42, and that the appeal period had lapsed because petitioner filed with the CA thirty‑one days after notice of the denial of reconsideration. The Court recited the settled requisites of certiorari and the general rule that certiorari and appeal are mutually exclusive, and reiterated that certiorari is not a substitute for appeal where the latter is available. The Court nonetheless recognized established exceptions allowing relaxation of procedural rules when public welfare, broader interests of justice, nullity of writs, or oppressive judicial action so require.

Supreme Court’s Merits Analysis on Ejectment and Deed Validity

Turning to the merits, the Court explained the limited purpose of ejectment proceedings under Rule 70 — to determine de facto possession — and emphasized that where ownership is raised the trial court must make a provisional determination for the limited purpose of resolving possession. The Court found that both the MeTC and the RTC failed to articulate the factual and legal bases of their conclusions and neglected to discuss, even provisionally, the validity of the DOAS and the authority of the alleged attorney‑in‑fact, issues expressly framed at preliminary conference.

Legal Basis for Invalidating the DOAS and Plaintiff’s Failure of Proof

The Court held that the DOAS suffered fatal legal infirmities that negated respondents’ asserted de facto possession. It observed that Quintin died on March 12, 1997 and that the DOAS bore the date August 20, 1997, thus the seller lacked contractual capacity at the time of execution and the sale could not validly transfer title. The Court recalled that agency to sell real property re

Case Syllabus (G.R. No. 217111)

Parties and Procedural Posture

Lilah Gail Corpuz Alfiler was the occupying defendant in an ejectment action and petitioner before the Court of Appeals and the Supreme Court.
Sps. John Cayabyab and Geraldine Cayabyab, represented by Attorney-in-Fact Jose Vasallo, were plaintiffs in the ejectment action and respondents in this petition.
The complaint for ejectment was filed in the Metropolitan Trial Court of Quezon City, Branch 43 on March 18, 2010, as reflected in Civil Case No. 40058.
The Metropolitan Trial Court rendered its Decision on January 3, 2011, in favor of the plaintiffs, which was affirmed by the Regional Trial Court of Quezon City, Branch 97 on January 9, 2013.
The RTC denied petitioner’s Motion for Reconsideration on October 17, 2013, and petitioner filed a petition for certiorari under Rule 65, Rules of Court, with the Court of Appeals on November 22, 2013.
The Court of Appeals dismissed the petition for certiorari in a Resolution dated December 13, 2013 and denied reconsideration on February 17, 2015, prompting the filing of this Rule 45 petition for review on certiorari with the Supreme Court.

Key Factual Allegations

The disputed parcel of land is located at No. 186 Pajo Street, Barangay Quirino 2-C, Quezon City, consisting of 266.9 square meters and covered by Transfer Certificate of Title No. RT-115646 (324155) in the name of Quintin Santiago, Jr. and his spouse Violeta E. Santiago.
On May 1, 1985 the registered owner and persons occupying the lot entered into an Amicable Settlement providing for a sale at P550.00 per square meter at a total price of P146,000.00 and contemplated staggered payments.
The predecessors-in-interest of petitioner allegedly furnished partial payments totaling P72,425.00 with the last payment in June 1986.
Quintin Santiago, Jr. died on March 12, 1997.
Respondents alleged they acquired ownership through a Deed of Absolute Sale dated August 20, 1997 executed by Quintin through an alleged Special Power of Attorney in favor of his attorney-in-fact Norman Santiago.
Respondents served a final demand to vacate dated May 8, 2009 and subsequently filed the ejectment complaint alleging unlawful possession since 1997.

Lower Court Decisions

The Metropolitan Trial Court rendered judgment on January 3, 2011 ordering petitioner and other defendants to vacate the premises, to pay Php 1,000.00 per month from May 8, 2009 until surrender, to pay Php 20,000.00 attorney’s fees, and costs of suit.
The MeTC found that defendants failed to prove their right to the property and that plaintiffs established ownership by a preponderance of evidence.
The Regional Trial Court, exercising appellate jurisdiction, affirmed the MeTC Decision in toto on January 9, 2013 and directed issuance of the writ of execution pursuant to Section 21, Rule 70 of the Rules of Court.
The RTC held that defendants failed to anchor their material possession on a claim of title and agreed with the MeTC that respondents established a better right.
The Court of Appeals dismissed petitioner’s Rule 65 petition on December 13, 2013 for being the wrong mode of appeal and denied reconsideration on February 17, 2015, rejecting petitioner’s plea for liberal application of procedural rules.

Issues Presented

Whether the Court of Appeals erred in dismissing petitioner’s petition for certiorari under Rule 65 as the wrong mode of appeal despite asserted compelling reasons to invoke a liberal construction in the interest of substantial justice.
Whether the Court of Appeals erred in refusing to give due course to the petition for certiorari notwithstanding the presence of matters requiring resolution on the merits.
Whether the Deed of Absolute Sale dated August 20, 1997 is void for lack of a valid and written Special Power of Attorney and because it was executed after the death of Quintin Santiago, Jr..
Whether the MeTC had jurisdiction over the ejectment action given th