Case Summary (G.R. No. 192893)
Applicable Law
This case primarily deals with the laws governing unlawful detainer as reflected in the 1987 Philippine Constitution and related statutes, including the Rules of Court and Batas Pambansa Blg. 129.
Background and Facts
On July 8, 2003, the heirs of Dionisio Delay and Praxedes Martonito filed a Complaint for Unlawful Detainer against MERALCO, concerning a parcel of land in Trece Martires City, inherited from their predecessors. The land was subject to a deed of donation executed on November 12, 1965, wherein a portion was donated to the Communications and Electricity Development Authority (CEDA) for electric supply provision. Following the sale of CEDA's assets to MERALCO in 1985, disputes arose regarding MERALCO's continued occupancy and the heirs' assertion of ownership over the land. A demand for MERALCO to vacate the property was made on May 19, 2003, which was ignored, prompting the unlawful detainer complaint.
Proceedings in Lower Courts
The Municipal Trial Court in Cities dismissed the unlawful detainer complaint, determining it lacked jurisdiction due to the need for interpreting the deed of donation, an issue not within its jurisdiction. The Regional Trial Court (RTC) upheld this decision, affirming that possession issues intertwined with ownership could not be resolved without examining the deed's terms.
Court of Appeals Decision
The Court of Appeals reversed the RTC's ruling, emphasizing that unlawful detainer actions focus on possession and are cognizant of possessory rights irrespective of ownership claims. The CA noted that MERALCO’s request to Dionisio for permission to occupy the land acknowledged the heirs' superior right to possession. Thus, MERALCO was ordered to vacate the subject land and pay monthly rentals to respondents.
Issues on Appeal
The Supreme Court was tasked with addressing:
- Whether the complaint stated a valid cause of action for unlawful detainer.
- The admissibility of extrinsic evidence recognizing the respondents' ownership against the deed of sale.
- The validity of the title transferred to MERALCO and any potential revocation of the donation.
Findings of the Supreme Court
The Supreme Court concluded that unlawful detainer was a proper remedy, highlighting that legal possession requires acknowledgment of any pertinent ownership claims. It affirmed that the MTCC possessed jurisdiction to preliminarily determine possessory rights, indicating extrinsic evidence, such as MERALCO's own letters, confirmed the respondents' ownership and undermined MERALCO's claims. The Court emphasized the importance of the
...continue readingCase Syllabus (G.R. No. 192893)
Case Overview
- This case involves a petition for review on certiorari by Manila Electric Company (MERALCO), seeking to overturn the Court of Appeals' decision which reversed a lower court's dismissal of an unlawful detainer case filed by the heirs of Dionisio Deloy and Praxedes Martonito against MERALCO.
- The challenge stems from the interpretation of property rights concerning a parcel of land utilized by MERALCO for its electric distribution operations.
Background and Facts
- On July 8, 2003, the respondents, heirs of Spouses Dionisio Deloy and Praxedes Martonito, filed a Complaint for Unlawful Detainer against MERALCO regarding a 680-square meter portion of an 8,550-square meter property in Trece Martires City.
- The property originally belonged to Dionisio Deloy, who donated the subject land to the Communications and Electricity Development Authority (CEDA) in 1965 to facilitate affordable electricity in Cavite.
- In 1985, CEDA sold its electric distribution system to MERALCO, which subsequently began occupying the subject land.
- MERALCO sought permission from Dionisio to continue using the land but failed to reach an agreement before his death in December 1985.
- After several years of inaction and failed negotiations,