Case Summary (G.R. No. 88158)
Nature of the Case
The case revolves around a Petition for Review on Certiorari under Rule 45 of the Rules of Court, aimed at overturning the Decisions and Resolutions of the Court of Appeals, which upheld the eviction of Haide Bulalacao-Soriano from a property she claims partial ownership of.
The Facts Involved
The property in question was originally owned by Tomas de Jesus and was sold by his heirs to Ernesto and Manuel Papina. Although the property was sold, the tax declarations remained under de Jesus's name. The Papina brothers allowed Haide to build a house on the property with the understanding that she would vacate if they required possession. Eventually, an agreement secured a loan to Haide from the Papina brothers using the property as collateral. There was a further complicated financial interaction when Manuel sold his share of the property to Haide without informing Ernesto.
Unpaid Taxes and Instruction from Manuel
Haide maintained that she paid real property and estate taxes amounting to P20,780 as directed by Manuel, who insisted that this amount would offset her remaining balance of P8,500 from the purchase price. The two parties disputed whether this instruction was valid, with Manuel denying any obligation toward Haide.
Ruling of the Municipal Trial Court
The Municipal Trial Court dismissed Ernesto's ejectment complaint for lack of jurisdiction, asserting that the unlawful detainer elements were not satisfied. The court indicated that determining land ownership required a higher authority than its jurisdiction provided.
Ruling of the Regional Trial Court
The Regional Trial Court reversed the Municipal Trial Court's ruling, finding sufficient elements for an unlawful detainer action. It agreed that the possession shifted from tolerance to unlawful dispossession upon the demand for Haide to vacate, and categorized the case as one of unlawful detainer.
Ruling of the Court of Appeals
The Court of Appeals upheld the Regional Trial Court's decision, asserting that the unlawful detainer suit was valid. It clarified that Haide's ownership through her agreement with Manuel was merely a proportionate share, emphasizing the distinctions inherent in undivided ownership.
The Issues
The central issue in this case is whether Ernesto has a legitimate case for unlawful detainer. Haide argues her right to possess the property stems from her agreement with Manuel, while Ernesto insists her right ceased when the Papina brothers partitioned the property through a formal agreement.
The Court's Ruling
The Supreme Court recognized the merits of Haide
...continue readingCase Syllabus (G.R. No. 88158)
Nature of the Case
- The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioner, Haide Bulalacao-Soriano, seeks to reverse the decision of the Court of Appeals (CA) which upheld her eviction from a property she claims part ownership of.
- The impugned decision and resolution of the CA were dated October 30, 2013, and May 29, 2014, respectively, in CA-G.R. SP No. 113098.
The Facts
- The property in question is a 201-square meter residential land located in Barangay VII, Daet, Camarines Norte, originally owned by Tomas de Jesus, as per Tax Declaration No. 2172.
- This property was sold by the heirs of De Jesus to Ernesto Papina and his brother, Manuel Papina, for P15,000, documented through an "Extrajudicial Settlement of Estate with Sale."
- Despite the sale, tax declarations remained under the name of De Jesus.
- Ernesto's father permitted Haide to build a house on the property with the provision that she would vacate if the owners required the land.
- The Papina brothers agreed to maintain co-ownership and not to partition the property.
- In 1993, the brothers mortgaged the property to Haide for a P25,000 loan, and Haide's possession continued without dispute until later issues arose over payments and ownership.
Subsequent Agreements and Transactions
- In 2000, Manuel sold his share to Haide for P100,000, which was to be paid in installments. This sale was documented in a "Kasunduan sa Bilihan ng Lupa" (Kasunduan).
- Haide made significant payments totaling P91,500, including the loan amount