Case Summary (G.R. No. 154203)
Background Facts
In 1974, the original owners allowed Remigio, Jr. and his children, including the petitioners, to occupy one unit of the duplex rent-free. In 1985, respondent Virgilio started to occupy the other unit under similar terms. Following the death of Remigio, Sr. in 1992, the surviving family members executed an extrajudicial settlement, wherein they waived their rights to several properties in favor of Consuelo Rivera. The property was sold to respondent Virgilio on April 6, 1999, for P500,000.00 while both parties resided in California.
Ejectment Proceedings
After the sale, respondent attempted to formalize the occupancy by proposing a lease contract for the unit occupied by the petitioners, but they refused to sign or vacate. Consequently, respondent initiated an unlawful detainer case against the petitioners in the Metropolitan Trial Court (MeTC) of Pasig City. The petitioners countered by claiming that the deed of sale was fictitious and asserted their right to occupy the property as co-owners.
Trial Court Decision
The MeTC ruled in favor of respondent, leading to an order for petitioners to vacate the property and pay unpaid rentals and attorney’s fees. Petitioners appealed this verdict to the Regional Trial Court (RTC), which initially sided with them, deeming there was no valid lease and recognizing their status as co-owners.
Court of Appeals Ruling
The Court of Appeals reversed the RTC’s decision and reinstated the MeTC’s ruling, emphasizing that respondent, as the registered owner, had the right to regain possession of the property. The appeal to the Supreme Court followed, wherein petitioners raised several issues including their right to remain in the property, the jurisdiction of the MeTC, and whether respondent held the property in trust for them.
Legal Analysis
The Supreme Court affirmed the Court of Appeals’ decision, indicating that prior physical possession was not a requisite for the plaintiff in unlawful detainer cases; rather, a showing of better right to possession suffices. The Court noted that while petitioners had actual possession, it was initially based on the original owners’ tolerance, which ended upon the sale to respondent.
Importantly, the occupancy was deemed unlawful due to their refusal to sign the lease after the sale and the execution of a contract representing that the previous owners had permit
...continue readingCase Syllabus (G.R. No. 154203)
Case Background
- This case concerns a petition for review under Rule 45 of the Rules of Court, filed by petitioners Rey Carlo A. Rivera and Gladys Abaga Rivera against respondent Virgilio Rivera.
- The dispute centers around a 228-square meter lot with a two-storey duplex house located in Pasig City, originally owned by spouses Remigio Rivera, Sr. and Consuelo Rivera.
- The couple had eleven children, including petitioners' father, Remigio, Jr., and the respondent, Virgilio Rivera.
- In 1974, the spouses asked Remigio, Jr. and his children (the petitioners) to occupy one unit of the duplex without paying rent, while respondent Virgilio occupied the other unit gratuitously after moving in 1985.
Events Leading to Dispute
- After the death of Remigio, Sr. in 1992, an extrajudicial settlement was executed by the heirs, wherein they waived their hereditary rights to certain properties, including the duplex, in favor of their mother Consuelo.
- In 1993, both Remigio, Jr. and respondent moved to the United States, leaving the petitioners in one unit of the duplex.
- On April 6, 1999, Consuelo sold the duplex house and lot to respondent for P500,000.00 while residing together in San Jose, California.
- Following the sale, respondent attempted to formalize the occupancy of petitioners by asking them to sign a lease contract, which they refused, leading to the filing of an unlawful detainer case.