Case Summary (G.R. No. 237720)
Factual Background
The dispute centers on a residential property, measuring 58.5 square meters, situated at New Antipolo Street, Tondo II-B, Manila. Demetria N. Domingo filed a Complaint for Unlawful Detainer against Alvin F. Samonte, claiming she purchased the property through a Deed of Sale executed on July 8, 2011. Samonte denied the sale, asserting he only took out a loan from Domingo for which he signed a document under the belief it was a mortgage contract. He claimed that Domingo took advantage of his financial distress.
MeTC Ruling
The Metropolitan Trial Court (MeTC) rendered a judgment on May 15, 2013, dismissing Domingo's complaint for Unlawful Detainer. The MeTC ruled Domingo failed to prove a lease contract existed between the parties or that a demand letter had been sent to Samonte. Thus, the case was dismissed for lack of cause of action.
RTC Ruling
Upon appeal to the Regional Trial Court (RTC), Branch 24, the MeTC ruling was reversed. The RTC found the MeTC made errors in dismissing the unlawful detainer action. It ruled that any person could file for unlawful detainer against someone holding possession without a legal right, thereby establishing Domingo's right of possession based on the claimed Deed of Sale. The RTC ordered Samonte to vacate the property.
CA Ruling
Samonte’s subsequent petition for review to the Court of Appeals affirmed the RTC's decision. The CA concluded that Domingo presented sufficient evidence supporting her claim of possessory rights and maintained that the ruling regarding possession was provisional, focused solely on the issue at hand.
Subsequent Developments
While the appeal was pending, Samonte initiated a separate action for the annulment of the Deed of Sale, leading to RTC Branch 32 declaring the deed void, reasoning that the transaction constituted an equitable mortgage. The CA subsequently affirmed this judgment, which became final on September 15, 2017.
Final Ruling of the Supreme Court
The Supreme Cour
...continue readingCase Syllabus (G.R. No. 237720)
Case Background
- This case involves a Petition for Review on Certiorari filed by Alvin F. Samonte (Petitioner) against Demetria N. Domingo, married to Daniel SB. Domingo (Respondent).
- The petition arises from the Decision of the Court of Appeals (CA), which affirmed the ruling of the Regional Trial Court (RTC) of Manila, Branch 24, that reversed the decision of the Metropolitan Trial Court (MeTC) of Manila, Branch 3.
- The subject of the controversy is a residential house made of light materials, covering an area of 58.5 square meters, located on New Antipolo Street, District of Tondo II-B, Manila.
Parties' Claims
- Demetria N. Domingo filed a Complaint for Unlawful Detainer against Samonte, claiming she purchased the property from him through a Deed of Sale executed on July 8, 2011.
- Domingo alleged that Samonte refused to vacate the property despite demands and even rented out portions of it to tenants.
- In his defense, Samonte denied the sale, asserting that he signed a document believing it to be a mortgage contract to secure a loan of P59,000.00 from Domingo, which he claimed was a result of being misled and defrauded.
Ruling of the MeTC
- On May 15, 2013, the MeTC dismissed Domingo's complaint for Unlawful Detainer due to:
- Lack of evidence establishing a lease contract between the parties.
- Absence of a demand letter sent to and received by Samonte.
- The M