Case Summary (G.R. No. 197728)
Factual Background
On August 17, 2007, the petitioners initiated an ejectment complaint against the respondent, asserting ownership of the condominium unit, which they purchased from three Indian nationals who had contractual rights to it. The petitioners alleged that the respondent, who had leased the unit, failed to remit rental payments totaling PHP 2,130,000.00 and ignored their demand to vacate. In response, the respondent acknowledged her lease but contended she was the actual purchaser of the unit through an agreement with Armando Trinidad, who she claimed registered the unit in his name under the understanding that it would be owned by her.
Procedural History
The Metropolitan Trial Court (MeTC) ruled in favor of the respondent, establishing her as the true owner of the condominium based on the intent expressed in the agreements and the evidence presented. The decision was appealed to the Regional Trial Court (RTC), which reversed the MeTC's ruling, favoring the petitioners. The Court of Appeals (CA) later reinstated the MeTC's decision, leading to the petitioners seeking a review from the Supreme Court.
Legal Issues Presented
The petitioners raised several legal issues, questioning whether the respondent’s evidence was sufficient to establish her ownership and whether an implied trust existed in her favor. The Court was also tasked with deciding on the procedural propriety of reviewing findings of fact.
Assessment of Ownership Claims
The Supreme Court clarified that the question at hand primarily dealt with possession related to claims of ownership. Citing established jurisprudence, the Court noted that while ownership determinations can guide possession issues, they do not conclude ownership disputes. As the legal review is constrained to questions of law, underlying factual disputes remain non-reviewable unless they fall into recognized exceptions, which were echoed in the reasoning.
Evaluation of Evidence
The Court evaluated the evidence presented by both parties, noting that while the petitioners relied heavily on the notarized Deed of Assignment and Transfer of Rights, the respondent presented substantial counter-evidence. This included checks, receipts for payments made by the respondent to the former owners, and acknowledgments of payments and ownership intentions that suggested a trust relationship. The Court underscored that while notarized documents hold prima facie weight, they can be contested by clear and convincing evidence demonstrating the parties' true intent.
Legal Interpretations
The Court addressed the principle of parole evidence, affirming its application in this context as the respon
...continue readingCase Syllabus (G.R. No. 197728)
Case Overview
- This case involves a petition for review on certiorari filed by petitioners Armando and Lorna Trinidad against respondent Dona Marie Glenn Imson, seeking to overturn the Court of Appeals' decision that reversed the Regional Trial Court's ruling in a dispute over possession of a condominium unit.
- The case was decided by the Supreme Court and the decision was promulgated on September 16, 2015.
Factual Background
- On August 17, 2007, the petitioners filed a complaint for ejectment against the respondent in the Metropolitan Trial Court (MeTC), asserting ownership of condominium unit 2203 located at AIC Gold Tower, Pasig City.
- Petitioners purchased the unit from three Indian nationals who had not fully paid the developer, AIC Realty Corporation, for the property.
- The purchase was evidenced by a Deed of Assignment and Transfer of Rights dated June 13, 2002, and a Deed of Absolute Sale dated July 13, 2007, registered in Armando's name.
- At the time of petitioners' acquisition, the unit was being leased to the respondent, with the lease agreement effective from April 1, 2002, to March 1, 2003.
- The petitioners claimed that the respondent failed to pay rent, accumulating arrears of P2,130,000.00, prompting their demand for her to vacate the premises.
Respondent's Position
- The respondent acknowledged her lease but claimed an intention to purchase the unit in June 2002. She alleged that Armando agreed to buy the unit on her behalf due to her marital issues and his trustworthiness.
- Respondent maintained that she made all payments for the purchase price through checks, handled real property taxes, and utility bills, thus asserting her ownership of the property.
- She was surprised by the petitioners' demand to v