Case Summary (G.R. No. 146364)
Petitioner and Respondent
Petitioner: Colito T. Pajuyo
Respondents: Court of Appeals (CA) and Eddie Guevarra
Key Dates
• June 1979 – Pajuyo’s acquisition and construction of house
• 8 December 1985 – Execution of Kasunduan
• 15 December 1995 – Metropolitan Trial Court (MTC) decision in Pajuyo’s favor
• 11 November 1996 – RTC Branch 81 affirmed MTC decision
• 13 December 1996 – Guevarra filed motion for extension with the Supreme Court
• 28 January 1997 – Court of Appeals granted 30-day extension
• 21 June 2000 – CA reversed RTC and dismissed ejectment case
• 14 December 2000 – CA denied Pajuyo’s motion for reconsideration
• 3 June 2004 – Supreme Court decision
Applicable Law
• 1987 Philippine Constitution (decision date post-1990)
• 1997 Rules of Civil Procedure: Rule 45 (petition for review), Rule 41, Rule 70 (ejectment)
• Civil Code: Articles 1933–1947 (commodatum), Articles 1411–1412 (pari delicto), Article 2208 (attorney’s fees)
• Proclamation No. 137 (7 September 1987) and the Code of Policies on socialized housing
Procedural History
- Pajuyo’s ejectment complaint filed in MTC, Branch 31.
- MTC (15 Dec 1995) ordered Guevarra to vacate, pay P300/month rental and P3,000 attorney’s fees.
- RTC, Branch 81 (11 Nov 1996) affirmed MTC decision.
- Guevarra filed untimely petition for review but secured a 30-day extension from CA (Resolution of 28 Jan 1997).
- CA (21 June 2000) reversed lower courts, declared both parties squatters in pari delicto and dismissed ejectment.
- CA denied reconsideration (14 Dec 2000).
- Pajuyo petitioned under Rule 45 to the Supreme Court.
Facts and Contractual Relationship
• Pajuyo paid P400 to Pedro Perez in 1979, but Perez held no valid title (public land).
• Pajuyo constructed the house; he and family occupied it until December 1985.
• The Kasunduan granted Guevarra free occupancy, bound him to maintenance, and required voluntary vacation on demand.
• Guevarra stayed until Pajuyo’s demand in September 1994, then refused to vacate.
Rulings of Lower Courts
MTC: Treated the Kasunduan as tolerance; held Guevarra’s continued occupation unlawful on demand.
RTC: Recognized landlord-tenant relationship under the Kasunduan; limited its inquiry to possession; rejected squatter defense under Proclamation No. 137.
CA: Labeled both parties squatters, invalidated any rights under Perez’s assignment or the Kasunduan; characterized the Kasunduan as commodatum; applied pari delicto; gave Guevarra priority under Proclamation No. 137.
Issues for Supreme Court Review
- Whether CA erred in granting Guevarra a 30-day extension when the RTC decision was already final.
- Whether CA should have dismissed the petition for review due to counsel’s—rather than petitioner’s—signature on the non-forum-shopping certification.
- Whether the Kasunduan is a commodatum, not a lease, and whether ejectment lacked factual and legal basis.
- Whether the parties being in pari delicto precluded relief.
- Whether Proclamation No. 137 and the Code of Policies, rather than the Kasunduan, governed the ejectment suit.
Procedural Issues Analysis
• The CA validly granted an extension for filing a petition for review (Lacsamana, Liboro, Commissioner of Internal Revenue). A petition for review requires verification and is not a mere notice of appeal; the CA may extend up to 15 days or longer in meritorious cases.
• The timeliness of Guevarra’s motion (received by the Supreme Court on 13 Dec 1996) fell within the 15-day period following the 29 Nov 1996 receipt of the RTC decision.
• Pajuyo’s late challenge to the certificate against forum shopping was an afterthought; failure to invoke the defect earlier estops him from now attacking jurisdiction.
• The absence of title does not defeat jurisdiction in ejectment, which concerns only de facto possession (Pitargue v. Sorilla).
Jurisdiction over Possession Disputes on Public Land
• Ejectment actions (forcible entry and unlawful detainer) are summary proceedings to protect prior possession and prevent breaches of the peace, regardless of title.
• Courts retain jurisdiction to resolve conflicts of physical possession even on public lands pending administrative award; refusal would encourage lawlessness among claimants.
Pari Delicto Principle Inapplicable
• The pari delicto rule disallows judicial aid to parties equally at fault in an illegal contract, but exceptions exist where public policy demands relief.
• Applying pari delicto to squatters in ejectment would nullify summary remedies and foster violent self-help.
Proclamation No. 137 and Beneficiary Selection
• Guevarra failed to prove the lot lies within the Proclamation’s metes and bounds or that he applied for socialized housing benefits.
• Even if a pending application existed, CA overreached by adjudicating administrative qualifications; courts must limit ejectment proceedings to physical possession.
Charac
Case Syllabus (G.R. No. 146364)
Antecedents and Facts
- In June 1979, petitioner Colito T. Pajuyo paid ₱400 to Pedro Perez for rights over a 250-sqm lot in Barrio Payatas, Quezon City, and built a light-material house thereon.
- Pajuyo and his family occupied the house from 1979 until 7 December 1985.
- On 8 December 1985, Pajuyo and private respondent Eddie Guevarra executed a Kasunduan: Guevarra was allowed to live rent-free in exchange for maintaining the premises and vacating on demand.
- In September 1994, Pajuyo demanded Guevarra to vacate; Guevarra refused.
- In his answer to the ejectment suit, Guevarra claimed neither he nor Pajuyo held valid title, asserting the lot lay within the 150 ha reserved by Proclamation No. 137 for socialized housing.
Procedural History
- 15 December 1995 (MTC Branch 31): Judgment for Pajuyo—ejectment; ₱300/month compensation from last demand; ₱3,000 attorney’s fees; costs.
- 11 November 1996 (RTC Branch 81): Affirmed MTC decision “en toto.”
- 29 November 1996: Guevarra received RTC decision; period to appeal expired 14 December 1996.
- 13 December 1996: Guevarra filed Motion for Extension of Time to File Appeal by Certiorari before the Supreme Court.
- 3 January 1997: Guevarra filed petition for review with the Supreme Court.
- 8 January 1997: Supreme Court referred the motion to the Court of Appeals (CA).
- 28 January 1997: CA Thirteenth Division granted the 30-day extension, subject to timeliness.
- 11 April 1997: Pajuyo filed comment.
- 21 June 2000: CA decision reversed RTC, set aside ejectment; held parties squatters in pari delicto.
- 14 December 2000: CA denied Pajuyo’s motion for reconsideration.
Issues Presented
- Did the CA err in granting Guevarra a 30-day extension after the RTC decision became final?
- Did the CA misapply forum-shopping rules by giving due course to a petition signed only by counsel?
- Was the Kasunduan a commodatum (as CA held) or a lease-like arrangement (as MTC/RTC held)?
- Could the CA declare the parties in pari delicto and refuse relief on that ground?
- Should the CA have applied Procl