Case Summary (G.R. No. 115758)
Procedural History
Following the Garcias’ return to the Philippines in 1995, they discovered that their property was occupied by the petitioners, who asserted that they had leased it from a previous owner. The Garcias initiated forcible entry proceedings by filing a complaint with the Metropolitan Trial Court (MeTC). The complaint was amended, and on November 11, 1997, the MeTC ruled in favor of the Garcias, ordering the petitioners to vacate the property, remove any constructions, and pay damages.
Appeal and Decisions
The petitioners filed an appeal to the Regional Trial Court (RTC) without a supersedeas bond, resulting in the Garcias seeking and eventually receiving a writ of execution. The RTC affirmed the MeTC's decision on April 28, 1999. The petitioners subsequently elevated the matter to the Court of Appeals, which dismissed their petition on January 26, 2000, and later denied their motion for reconsideration on April 10, 2000.
Legal Issues Raised
The petitioners claimed several errors by the Court of Appeals, notably: (1) ruling on ownership despite the primary focus being possession, (2) failing to acknowledge their prior physical possession, (3) disregarding their evidence of ownership, and (4) irregularities concerning the writ of demolition issued by the RTC.
Court’s Analysis of Ownership vs. Possession
The Court reiterated that the primary issue in ejectment cases is the right to actual possession rather than ownership. However, when possession claims are intertwined with ownership questions, the court can address ownership to resolve the possession issue. The petitioners’ defense raised ownership claims, thus justifying the appellate court’s exploration of ownership.
Prior Possession and Evidence Assessment
The Court found no merit in the petitioners' argument regarding prior possession based on the Court of Appeals’ interpretation, which categorized their references as allegations rather than established facts. This led to the conclusion that the findings on possession were consistent with the evidence favoring the respondents.
Evidentiary Value and Credibility
The Court addressed concerns regarding the documentary evidence presented by the petitioners, including a Deed of Sale and a Special Power of Attorney. However, it noted that these documents were inadmissible due to lack of original copies and failure to comply with evidentiary requirements, weakening the petitioners' case.
Affirm
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Case Overview
- The case involves a petition for review filed by Octavio Alvarez, Marilyn Cortez, and Charlie Robles, seeking to reverse the decision of the Court of Appeals dated January 26, 2000, and its resolution dated April 10, 2000, which denied the petitioners' motion for reconsideration.
- The focal point of the case is a dispute over a parcel of land in Quezon City, which the respondents, Domingo and Celia Garcia, claim to own and which they allege was wrongfully occupied by the petitioners.
Factual Background
- On May 15, 1978, Domingo and Celia Garcia purchased Lot 23, Block 6, San Beda Subdivision, Quezon City, with an area of 405 square meters, evidenced by Transfer Certificate of Title (TCT) No. 221634.
- The Garcias registered the property and erected a fence around it before relocating to the United States due to Domingo's employment.
- Upon returning in February 1995, Celia discovered the fence had been removed and parts of their property were occupied by individuals who had built makeshift houses.
- The occupants, Marilyn Cortez and Charlie Robles, claimed they were leasing the property from Octavio Alvarez, who purportedly bought it from Amparo Lasam.
Legal Proceedings
- The Garcias filed a complaint for forcible entry against the occupants in the Metropolitan Trial Court (MeTC) of Quezon City, later amending it to include only Alvarez, Cortez, and Robles.
- On November 11, 1997, the MeTC ruled in favor of the Garcias, ordering the defendants to vacate the property and remove all improvements, along with monetary compensation for unauthorized use.
- The petitioners appealed the MeTC decision to the Regional Trial Court (RTC) without filing a supersedeas bond, leading