Case Summary (G.R. No. 197058)
Statement of Facts
In May 2008, Gregory Baluyo filed a complaint against the De La Cruz spouses, asserting that he was the caretaker of the property purchased by his brother. The respondents, however, argued that they have legitimate ownership as it belonged to Rebecca's deceased father, Bonifacio Dimaano. The Municipal Trial Court (MTC) initially ruled in favor of the petitioner, directing the respondents to return possession and awarding damages. This decision was upheld by the Regional Trial Court (RTC), which recognized the validity of the Deed of Absolute Sale presented by the petitioner.
Court of Appeals Ruling
Upon appeal, the Court of Appeals (CA) reversed the RTC's ruling, concluding that the petitioner did not sufficiently prove his prior physical possession of the property, an essential element in forcible entry cases. The CA highlighted that the petitioner failed to demonstrate which specific portion of the land was conveyed to him, undermining his claim of lawful possession.
Petitioner's Arguments
In his petition for review on certiorari, the petitioner contended that the CA misinterpreted the factual circumstances of the case, emphasizing that the family had lived on the property since 1970 and established claims of ownership through the Deed of Absolute Sale. He claimed that the identification of the half-portion of the property conveyed was evident, as the respondents had acquired the other half from the Dimaano spouses.
Respondents' Counterarguments
The respondents countered that the evidence provided by the petitioner was self-serving and lacked corroboration, arguing that the Deed of Absolute Sale was questionable, including concerns over its notarization and its appearance nine years after its purported execution.
Judicial Ruling
The Supreme Court found the petition meritorious, underscoring that proof of prior physical possession is requisite in forcible entry cases. It reiterated that the petitioner, despite any challenges to ownership, could claim possession if he was previously in possession. The Court ruled that the notarized deed provided strong evidence supporting the petitioner's claims, enjoying a presumption of regularity, which the respondents failed to overcome.
Analysis of Ownership Claims
The Court acknowledged that both parties asserted ownership over the property, with the petitioner relying on the Deed of Absolute Sale executed in November 1999 and the respondents affirming their claim through succession, as Rebecca was the sol
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Background of the Case
- The case involves a petition for review on certiorari filed by Gregory Baluyo y Gamora on behalf of his brother Emmanuel Gamora Baluyo against spouses Joaquin and Rebecca De La Cruz.
- The petition contests the decisions of the Court of Appeals dated October 22, 2010, and May 9, 2011, which reversed the favorable ruling of the Regional Trial Court (RTC) that had upheld the Municipal Trial Court (MTC) decision in a forcible entry case.
- The issue centers on the petitioner’s alleged failure to prove his prior physical possession of the disputed property, a critical element in forcible entry actions.
Statement of Facts
- In May 2008, Gregory Baluyo filed a complaint for forcible entry claiming he was the caretaker of a residential house and lot owned by his brother Emmanuel in Barangay San Pablo, Calabanga, Camarines Sur.
- The property was purchased by Emmanuel from Bonifacio and Consolacion Dimaano on November 30, 1999.
- The house had been leased to Lourdes Perico since March 2008, but on April 23, 2008, the respondents allegedly demolished the house and forcibly evicted the lessee.
- The respondents contested the ownership, asserting that the property rightfully belonged to Bonifacio Dimaano, Rebecca's father, who was the title holder.
Initial Rulings
- Municipal Trial Court (MTC):
- Ruled in favor of the petitioner, ordering the responde