Case Summary (G.R. No. 196529)
Relevant Background
The partnership that included William’s brother, Jimmy, and Looyuko was formalized through written agreements dating back to February 9, 1982. In 1986, William began occupying the townhouse as part of his position at Noahas Ark Sugar Refinery, which was co-owned by the partners. In 1998, Looyuko demanded that William vacate the property, citing his ownership evidenced by a Transfer Certificate of Title (TCT). However, Jimmy claimed co-ownership, leading to this dispute.
Course of Legal Proceedings
Looyuko filed a complaint for unlawful detainer against William in the Metropolitan Trial Court (MeTC), asserting that William's possession was only by tolerance. The MeTC ruled in favor of Looyuko, who thereafter sought immediate execution of the ruling. This was contested by William on the grounds of pending litigation concerning his brother's claim of co-ownership. The Quezon City Regional Trial Court (QC RTC) favored William, halting the unlawful detainer proceedings until ownership could be resolved. The Court of Appeals (CA) later reversed this decision, ruling that ownership issues did not preclude proceedings regarding possession.
Court of Appeals Decision
The CA held that ownership issues could be dealt with in subsequent litigation if necessary but that possession could be decided independently based on existing ownership documentation from Looyuko. They asserted that William could not challenge its validity within the unlawful detainer context. The CA ruled in favor of Looyuko, stating he was entitled to possession due to his registered ownership evidenced by the TCT.
Arguments of the Petitioner
William contended that the QC RTC had correctly assessed the evidence showcasing co-ownership by Jimmy and that the CA’s independence of possession from ownership was erroneous. He argued that ownership claims arose from legitimate evidence and that unlawful detainer actions required the plaintiff to have previously held physical possession.
Supreme Court's Ruling
The Supreme Court found William’s arguments lacking in merit, emphasizing that it may only review questions of law under Rule 45 of the Rules of Court, and not re-evaluate evidence presented in lower courts. The Court underscored that unlawful detainer proceedings primarily concern the physical possession of property. The presence of a TCT favoring Looyuko meant that he had an indefeas
...continue readingCase Syllabus (G.R. No. 196529)
Case Citation
- Jurisprudence: 713 Phil. 125
- G.R. No. 196529
- Date: July 01, 2013
- Court: Supreme Court of the Philippines
Parties Involved
- Petitioner: William T. Go
- Respondents: Alberto T. Looyuko, substituted by his legal heirs (Teresita C. Looyuko, Alberto Looyuko, Jr., Abraham Looyuko, Stephanie Looyuko, minors represented by their mother, Teresita Looyuko), and others (Alvin, Amos, Aaron, David, Solomon, and Noah Padecio).
Procedural History
- This case arises from a petition for review on certiorari under Rule 45 of the Rules of Court.
- The petition challenges the October 29, 2009 Decision and the March 30, 2011 Resolution of the Court of Appeals (CA), which set aside the March 29, 2004 Decision of the Regional Trial Court (RTC), Branch 88, Quezon City, and reinstated the May 20, 2000 Decision of the Metropolitan Trial Court (MeTC), Branch 35, Quezon City, regarding an action for unlawful detainer.
Factual Background
- Partnership: Respondent Alberto T. Looyuko and Jimmy Go, brother of petitioner William Go, were partners in a business named Noahas Ark Group of Companies, formalized in a written partnership agreement dated February 9, 1982.
- Occupancy: In 1986, William was appointed Chief of Staff of Noahas Ark and was allowed by Looyuko to occupy a townhouse in Gilmore Townhomes.
- Demand for Vacation: On October 28, 1998, Looyuko demanded that William vacate the townhouse. Subsequently, Jimmy filed an adverse claim over the property, asserting that it was purchased using partnership funds and thus belonged to Noahas Ark.
- Compla