Case Summary (G.R. No. 117389)
Factual Background
The disputed property, designated as Lot 1, Block 2, was originally part of a larger parcel covered by Transfer Certificate of Title No. 26604, co-owned by Manuel Melencio (1/3), Pura Melencio (1/3), and Wilfredo and Mariabelle Wico (1/3). Subsequently, TCT No. 26604 was cancelled, and TCT No. 65031 was issued in the name of petitioner Ramon S. Melencio, who acquired a share through a deed of sale from his deceased father. Respondent Juan S. Esteban acquired the property from Mauricio Ramos, who claimed to obtain it from Ursula Melencio, the administratrix of the estate of Manuel and Pura Melencio.
Ejectment Proceedings
On July 4, 1991, Esteban filed an ejectment suit against petitioner Oblea in the Municipal Trial Court of Cabanatuan City, leading to a ruling against Oblea on April 3, 1992. The lower court ordered him to vacate the premises and pay rental arrears, which was later modified on March 26, 1993, by the Regional Trial Court to limit these arrears to payments due only from March 2, 1988. Following this, Oblea acquired the disputed property on June 3, 1993.
Subsequent Legal Actions
After Oblea and Melencio, along with other co-owners, filed an action for quieting of title against Esteban, the ejectment case was appealed but ultimately dismissed by the Court of Appeals on July 2, 1993. Upon remand, the Municipal Trial Court ordered execution of the judgment, leading to the lifting of a temporary restraining order issued in favor of the petitioners.
Court of Appeals Decision
The decision by the Court of Appeals on September 27, 1994, emphasized that the ejectment case was final and executory, dismissing the petitioners' argument that their subsequent purchase and the doctrine of supervening events negated Esteban's rights. The appellate court concluded that the only issue in an ejectment case pertains to physical possession, not ownership, thus ruling that the execution of the ejectment judgment could not be delayed merely because a separate action for quieting of title was pursued.
Rationale for Decision
The core legal principle reaffirmed by the Court of Appeals was that the substantive issue for resolution in unlawful detainer actions focuses solely on actual possession—referred to as possession de facto—rather than ownership, which is outside the scope of such proceedings. The court determined that a subsequent acquisit
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Case Overview
- This case involves a petition for review on certiorari against a decision made by the Court of Appeals.
- The decision dismissed a petition for certiorari and prohibition and denied a request for a preliminary injunction against an order from the Regional Trial Court of Cabanatuan City.
- The order in question was dated April 6, 1994, and lifted a temporary restraining order issued by Municipal Trial Court Judge Lydia B. Hipolito.
Background of the Property Dispute
- The contested property, designated as Lot 1, Block 2, was originally part of a larger lot covered by TCT No. 26604, which was jointly owned by Manuel Melencio, Pura Melencio, and Wilfredo and Mariabelle Wico.
- TCT No. 26604 was later cancelled, and TCT No. 65031 was issued to Ramon S. Melencio, following a deed of sale from his deceased father, Manuel Melencio.
- On June 6, 1958, private respondent Juan S. Esteban purchased the lot from Mauricio Ramos, who claimed to have acquired it from Ursula Melencio, alleged administratrix of the Melencio estate.
Lease and Ejectment Proceedings
- Petitioner Romeo V. Oblea leased a building on the subject lot from Marius Esteban, purportedly the son of Juan S. Esteban.
- Oblea later bought the lot from Marius Esteban.
- On July 4, 1991, Esteban filed an ejectment suit against Oblea, leading to Civil Case No. 10588 in the Municipal Trial Court.
- The case was initially decided in favor of Esteban, with Oblea bei