Case Summary (G.R. No. 169380)
Background of the Dispute
The case revolves around a parcel of land registered in the name of Rodolfo Chua Sing under Transfer Certificate of Title No. 52594, covering an area of 1,919 square meters in Barangay San Dionisio, Parañaque City. Chua Sing purchased the property in 1991 and subsequently leased it to the petitioner on April 1, 1999, under a contract that was not notarized or registered. Significantly, the respondents were already occupying the land before the lease agreement was executed.
Procedural History and Initial Rulings
Following the execution of the lease, the petitioner demanded the respondents vacate the property within 30 days and pay rental fees but received a refusal. Consequently, the petitioner filed an ejectment case on October 20, 1999, in the Metropolitan Trial Court (MeTC) of Parañaque City, which ruled in favor of the petitioner. The Regional Trial Court (RTC) upheld this ruling on appeal, affirming that a case for unlawful detainer was appropriate as the respondents occupied the land merely by tolerance.
Court of Appeals Decision
However, the Court of Appeals, in its ruling dated March 14, 2005, reversed the lower courts' decisions, stating that the respondents' possession was not based on the petitioner's or his lessor's tolerance. The appellate court emphasized that the respondents had been in possession of the land prior to the lessor's purchase, indicating that their entry could not be characterized as unauthorized. The Court of Appeals concluded that the complaint for ejectment should be dismissed as it was essentially an action for recovery of possession, not unlawful detainer.
Issues Raised in Appeal
In the subsequent appeal to the Supreme Court, the petitioner raised three main issues regarding whether the Court of Appeals erred in dismissing the case based on its characterization of the nature of the action, the respondents' change of theory, and the merits of the case.
Supreme Court’s Ruling
The Supreme Court upheld the Court of Appeals' ruling and clarified that unlawful detainer is a summary action concerning the recovery of possession, which applies when the initial possession was legal, transitioning to illegal following a demand to vacate. The Court highlighted that the allegations made in the complaint suggested that the respondents' possession was unlawful from its inception, contradicting the requirements for an action of unlawful detainer.
Legal Principles Confirmed
The Court reaffirm
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Case Overview
- This case involves a petition for review on certiorari filed by Fiorello R. Jose against multiple respondents concerning a decision by the Court of Appeals.
- The petition challenges the appellate court's reversal of prior decisions from both the Regional Trial Court (RTC) and the Metropolitan Trial Court (MeTC) that had ruled in favor of Jose in an ejectment case.
Background and Facts of the Case
- The subject of the dispute is a parcel of land located in Barangay San Dionisio, ParaAque City, registered under Transfer Certificate of Title No. 52594 in the name of Rodolfo Chua Sing.
- Chua Sing purchased the land in 1991 and leased it to Jose on April 1, 1999, under a contract that was neither notarized nor registered.
- The lease contract allowed for a five-year term and specified that Jose would be responsible for evicting any occupants, despite the respondents already occupying the property before the lease was executed.
Procedural History
- Jose demanded that the respondents vacate the property on April 28, 1999, but they refused.
- Consequently, Jose filed an ejectment case against the respondents on October 20, 1999, before the MeTC, where no prior barangay proceedings were mentioned.
- After obtaining a Certification to File Action from the barangay, Jose filed an amended complaint which reinforced his claim as the lessee with the right to eject respo