Case Summary (G.R. No. 148759)
Applicable Law
The relevant legal framework includes the 1987 Philippine Constitution and the Rules of Court, specifically the provisions governing actions for unlawful detainer and accion publiciana.
Background and Procedural History
The petitioners initiated an ejectment case against the respondent on the ground that he had unlawfully withheld possession of the property after the expiration of a verbal lease agreement. The tenant occupied the property under a verbal contract since 1981, and the lease was terminated by a demand letter sent on July 1, 1995. The case progressed through the Metropolitan Trial Court and the Regional Trial Court, where the petitioners initially succeeded, but the Court of Appeals later reversed this decision, prompting the current appeal.
Decision of the Regional Trial Court
On September 30, 1998, the Regional Trial Court ruled in favor of the petitioners, ordering the respondent to vacate the property and pay rental arrears. The court found that the respondents' occupancy became unlawful after he stopped paying rent in July 1995, following the notice to vacate.
Court of Appeals' Ruling
In a subsequent appeal, the Court of Appeals dismissed the case, asserting that the proper action should have been one for unlawful detainer, as it determined that the petitioners had filed under accion publiciana prematurely. The appellate court held that the one-year period for filing an unlawful detainer case had not expired at the time the petitioners initiated their complaint.
Argument of the Petitioners
The petitioners challenged the appellate court's decision, arguing that the lower court had the jurisdiction to hear their case since the complaint was based on a clear cause of action for the unlawful withholding of possession. They asserted that the expiration of the lease contract constituted a valid legal basis to initiate the action for recovery of possession.
Jurisdictional Considerations
The Supreme Court emphasized that the allegations in the complaint determine the nature of the action and the jurisdiction over the case. It noted that the demand for possession served to terminate the month-to-month lease effectively and that the complaint was sufficient to invoke the jurisdiction of the Regional Trial Court based on the unlawful deprivation of possession.
Legal Principles Governing Ejectment Cases
Key principles regarding ejectment are discussed, including the classification of unlawful detainer and accion publiciana. The one-year period for unlawful detainer actions begi
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Case Overview
- The case involves a petition for review on certiorari under Rule 45 of the Rules of Court.
- Petitioners Germelina Torres Racaza and Bernaldita Torres Paras seek to nullify the decision dated July 12, 2000, and the resolution dated June 28, 2001, rendered by the Court of Appeals (CA).
- The CA's decision reversed and set aside the Regional Trial Court (RTC) decision dated September 30, 1998, which had ruled in favor of the petitioners in their complaint for accion publiciana against respondent Ernesto Gozum.
Background of the Case
- Petitioners are the registered co-owners of a parcel of land in Pasig City, previously owned by their late father, Carlos Torres.
- Ernesto Gozum occupied a portion of the property under a rental agreement of P3,500.00 monthly, continuing even after Carlos Torres's death in 1993.
- After several demands and a failed barangay conciliation, petitioners filed an ejectment case against Gozum, which was dismissed due to technicalities.
- Following another demand letter in May 1997, petitioners initiated the current complaint for recovery of possession on June 4, 1997.
Proceedings and Arguments
- Gozum's initial response was to file a motion to dismiss, claiming the RTC lacked jurisdiction and that the action should be for unlawful detainer.
- The RTC denied the motion, stating that because the action was initiated more than a year after the notice to vacate, it was properly an accion publiciana.
- Gozum asserted he had a 10-year contract of lease w