Case Summary (G.R. No. 222297)
Antecedents
On October 12, 2012, the respondents initiated a complaint for unlawful detainer against the petitioner in the Municipal Trial Court (MTC) of Bulacan, asserting ownership of a residential house situated on a 289-square meter lot owned by the petitioner and his wife, Carolina Anzures. The respondents contended that they had tolerated the petitioner's occupation of the property, which was hindering the partition of the land, despite repeated demands for vacating the premises. The petitioner, in his defense, claimed ownership of the house and land, claiming he purchased it from Erlinda Ventanilla and disputed the legitimacy of a deed of donation executed in favor of Erlinda by his late wife.
MTC Ruling
On August 16, 2013, the MTC ruled in favor of the respondents, ordering the petitioner to vacate and pay compensation and attorney fees. The MTC found that the respondents, as the owners, had merely tolerated the petitioner’s possession and granted favor to the respondents' cause of action for unlawful detainer.
RTC Ruling
The RTC, on June 30, 2014, upheld the MTC decision, confirming that the respondents had a superior claim to the property and that the petitioner’s occupancy stemmed from their tolerance. The RTC reiterated that possession becomes unlawful if the occupant refuses to vacate upon demand from the owner.
CA Ruling
The Court of Appeals denied the petition filed by the petitioner, affirming the RTC’s ruling. The CA concluded that the respondents sufficiently established a case for unlawful detainer, and the petitioner’s claims of forgery regarding the deed of donation were unsubstantiated, as he failed to provide convincing evidence.
Issues Raised
The petitioner raised two primary issues for review:
- Whether the CA erred in upholding the respondents’ cause of action for unlawful detainer based on tolerance.
- Whether the CA was correct in affirming the validity of the deed of donation dated March 21, 2011.
The Court's Ruling
The Supreme Court found in favor of the petitioner, indicating that the CA erred in its findings. In determining the issue of possession, the Court highlighted that the unlawful detainer action centered on who possessed superior rights to the property, noting that the petitioner's co-ownership was not adequately taken into account. It clarified that a co-owner cannot be ejected from the property based solely on the claim of another co-owner without adequate partition proceedings.
Recovery of Possession
The Court asserted that unlawful detainer, while concerned with maintaining possession, does not resolve ownership disputes. Since both parties presented claims of ownership, the Court maintained that any possible remedy involves legal partitioning of the shared property rather than ejectment.
Co-Ownership of the Property
The Court determined that the petitioner shared ownership right
...continue readingCase Syllabus (G.R. No. 222297)
Case Overview
- This case involves an appeal by certiorari from Fortunato Anzures (petitioner) seeking to reverse the decisions of the Court of Appeals (CA) which upheld the ruling of the Regional Trial Court (RTC) regarding an unlawful detainer action filed by Erlinda and Arturo Ventanilla (respondents).
- The CA's decision, dated July 24, 2015, and a subsequent resolution from December 18, 2015, confirmed the RTC's judgment that favored the respondents.
Antecedents
- On October 12, 2012, the respondents filed a Complaint for Unlawful Detainer against the petitioner in the Municipal Trial Court of Bulacan.
- Respondents claimed ownership of a residential house in Barangay Sta. Ines, Bulakan, Bulacan, which they alleged was built on a 289 square meter parcel of land partly owned by the petitioner and his late wife, Carolina Anzures.
- The respondents asserted that the petitioner was merely tolerated to occupy the property, and they sought his eviction after unsuccessful demands and attempts at amicable settlement.
- The petitioner countered that he was the rightful owner of the property, denying the legitimacy of the deed of donation, which he claimed was forged.
The MTC Ruling
- On August 16, 2013, the Municipal Trial Court ruled in favor of the respondents, ordering the petitioner to vacate the premises and pay monthly compensation and attorney's fees.
The RTC Ruling
- The RTC affirmed the MTC's ruling on June 30, 2014, asserting that respondents had a better right over the property and that the petitioner’s possession was tolerated.
The CA Ruling
- The CA denied the petitioner’s appeal, finding that the