Case Summary (G.R. No. 127850)
Background of the Case
The petitioners filed a complaint for unlawful detainer against the respondents on August 31, 1995, in the Municipal Trial Court of Tanza, Cavite, concerning a property covered by Transfer Certificate of Title No. 26277. The petitioners claimed that the respondents occupied the property through implied permission but without any contractual agreement. They noted that no rental fee had been collected from the respondents for their occupancy since it began.
Previous Legal Proceedings
The case history involves multiple legal actions. Notably, a related ejectment suit (Civil Case No. 285) filed by the petitioners in 1984 against the respondents was later dismissed on appeal, and a civil case for annulment of title filed by the respondents (Civil Case No. TM-59) against the petitioners was dismissed for failure to prosecute. The dismissal of this case was affirmed but was then followed by a new civil case (TM-146) filed by Lucio Ricafrente Arvisu that also challenged the petitioners' title.
Decisions of the Municipal Trial Court and Regional Trial Court
The Municipal Trial Court ruled in favor of the petitioners, ordering the respondents to vacate the property, remove any improvements, and pay damages. This decision was affirmed by the Regional Trial Court, but the respondents appealed to the Court of Appeals. The appellate court granted the appeal, claiming that the action did not constitute unlawful detainer due to previous legal proceedings favoring the respondents' claims of ownership.
Court of Appeals and Reversal of Rulings
The Court of Appeals held that unlawful detainer was not the proper remedy, emphasizing that the previous complaints indicated the tolerance allegedly granted by the petitioners had been withdrawn in 1984. It reasoned that since there had been a challenge against the ownership of the land, it was improper to classify the case as one of unlawful detainer.
Supreme Court Review
Upon review, the Supreme Court overturned the Court of Appeals' decision, stating that the nature of the action and jurisdiction were determined by the allegations in the complaint. The court emphasized that the action for unlawful detainer remains valid if it involves physical possession and the demand to vacate was made, which took place after the finalization of previous cases.
Legal Principles Established
The Supreme Court reiterated several legal principles related to unlawful detainer actions. It maintained that mere claim of ownership does not preclude summary proceedings for possession and that the original unlawfulness of
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Case Citation
- Jurisprudence: 348 Phil. 813
- G.R. No. 127850
- Date of Decision: January 26, 1998
- Court: First Division
Parties Involved
- Petitioners: Maria Arcal, Josefina Arcal, Marciana Arcal, and Virgilio Arcal
- Respondents: Court of Appeals, Danilo Bucal, Costan & Letty Ricafrente, Renie & Ceny Ricafrente, Sancho & Lanie Ricafrente, Cora Gonez, Solly Gonez, Enie and Florida Ricafrente, Carmen Tamboc, Boy Aguilar, Norming Arcal, Nora and Alex Bocita, Elvie Tahimic, Anchang Arguson, Idreg and Julia Arguson, Liza Arguson, Acion Arguson, Baleng and Fely Arguson, Fideng and Cileng Murania, Rosie and Aldo Calago, Engay and Shirley Ricafrente, Nenita and Narsing Aguilar, Odie Doza, Neneng and Ramon Lungcay, Tisay and Abet Dones, Yolly and Ed Paulino, Eric and Jennifer Paulino, Charlie Panganiban, Delia and Patricio Bueza, Ellen Dueza, Berting and Norma Bueza, Alice and Pilo Ricafrente, Delly and Fredo Nunez, Andro and Ellen Jimenez, Criselda and Gorio Clarete, Nena Velasco, Danny Clarete, Erlin and Nonong Ibong, Chita and Restie Reyes, Sonny and Dong Reyes, and Wally and Daisy Reyes.
Background of the Case
- Nature of the Case: The petition seeks the review of a decision by the Court of Appeals regarding a complaint for unlawful detainer.
- Initial Complaint: Filed on August 31, 1995, by the petitioners against the private respondents in the Municipal Trial Court of Tanza, Cavite concerning a parcel of land (Lot No. 780) covering 21,435 square meters, registered under Transfer Certificate of Title No. 26277.
- Allegations: Petitioners claimed that the respondents oc