G.R. No. 247973 - People vs. Samson y Cruz

May 2005 – Spouses Barbarona filed a Complaint for Ejectment in the Mandaue City Municipal Trial Court, alleging that the Sanitarium and others occupied the property by mere tolerance.
September 2005 – MTCC rendered judgment for respondents, ordering occupants to vacate and pay compensation, litigation expenses, and attorney’s fees.
November 2006 – Regional Trial Court affirmed the MTCC decision. Affected parties appealed to the Court of Appeals.
February 2007 – In a separate petition, the Court of Appeals annulled Decree No. 699021 and derived titles (including TCT 53698) for lack of notice to occupants.
April 2007 – RTC denied the Sanitarium’s motion for reconsideration.
February 2011 – Court of Appeals in the ejectment case denied the Sanitarium’s Petition for Review, upholding the RTC’s affirmation of the MTCC decision.
May 2011 – The Supreme Court issued a Temporary Restraining Order on execution of the CA decision.
August 2011 – Court of Appeals resolved a pending motion for reconsideration, which the Sanitarium had attempted to withdraw.
April 2018 – The Supreme Court granted certiorari to resolve procedural and substantive issues.

Whether the nullification of TCT No. 53698 invalidated respondents’ right of possession over the property.
Whether respondents’ ejectment complaint was properly one for unlawful detainer or should have been an accion publiciana.

The Office of the Solicitor General filed a Petition for Review with the Supreme Court while a Motion for Reconsideration remained pending before the Court of Appeals.
Under CA Internal Rules (Rule VI, § 15), a motion for reconsideration is deemed abandoned upon filing a petition for review in the Supreme Court; no formal approval by the CA is required.
Although the Solicitor General mistakenly sought formal withdrawal of the CA motion, petitioning the Supreme Court did not constitute willful forum shopping. The CA resolution on the motion for reconsideration thus had no legal effect, and the Supreme Court properly proceeded to the merits.

Ejectment proceedings focus on actual possession, not ownership. A Torrens certificate is prima facie evidence of ownership and incidentally supports a right to possession, but its subsequent annulment on procedural grounds does not, by itself, deprive a party of the underlying decree’s prima facie force.
Here, even if TCT No. 53698 were void, respondents’ right of possession under Decree No. 699021 remained, subject to final determination of ownership. Moreover, portions of Lot No. 1936 had been reserved by law for the Sanitarium under Proclamation No. 507 (1932), further protecting its occupancy.

Unlawful detainer requires proof that possession was initially lawful and became unlawful only upon demand to vacate. Acts of tolerance must be specifically alleged and proven, along with the period from initial entry to dispossession. The one-year prescriptive period begins upon demand to vacate. Jurisdiction lies with the MTCC.
Accion publiciana is a plenary action to recover a right of possession when an ejectment remedy is unavailable (e.g., when dispossession exceeds one year) and must be filed in the Reg