Umpoc v. Mercado
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the possession of a four-unit apartment located at 1120-1126 Don Quijote Street, Sampaloc, Manila. The respondent, as administratrix of the estate of the late Dr. Jesusa Barrios, sought to eject the petitioners, who were occupants of the apartment units. The petitioners claimed a right to possess the property based on a Deed of Sale dated March 30, 1987, allegedly executed by Dr. Barrios in favor of co-owners from whom they derived their right. The respondent asserted that the property was still part of Dr. Barrios's estate and that the petitioners' possession was merely by tolerance, demanding they vacate and pay rentals. 2. Procedural History: The respondent, Mildred Mercado, was appointed administratrix of the estate of Dr. Jesusa Barrios. Armed with this authority, she filed three separate unlawful detainer cases against the petitioners, Minerva Umpoc, Atty. Ildebrando Viernesto, and Ethel Manaloto, before the Metropolitan Trial Court (MeTC) of Manila. The MeTC ruled in favor of the respondent, ordering the petitioners to vacate and pay rentals, finding the alleged Deed of Sale to be unregistered and their possession to be by tolerance. The Regional Trial Court (RTC) affirmed the MeTC's decision and granted execution. The Court of Appeals, in turn, affirmed the RTC's ruling, denying the petitioners' motion for reconsideration. The petitioners' claim that a new Transfer Certificate of Title (TCT) was issued in the names of the alleged co-owners after the RTC decision was noted but did not alter the lower courts' findings regarding possession. 3. The Petition: The petitioners seek a review of the Court of Appeals' decision and resolution. They argue that the appellate court erred in holding that a lessor-lessee relationship existed, that their right to possess could not be based on the unregistered Deed of Sale, that the property remained part of the estate despite the alleged sale, and that the ejectment cases could not be suspended pending resolution of a separate annulment case. The core of their petition is that the lower courts lacked jurisdiction, that there was no cause of action for unlawful detainer, and that they, not the respondent, had the better right of possession based on the 1987 Deed of Sale and the subsequent transfer of title. They contend that the appellate court erred in giving precedence to the TCT in the decedent's name over the unregistered deed of sale and in not considering the issuance of a new TCT as a supervening event.
Issue(s)
Whether there is a cause of action for unlawful detainer and whether the MeTC has jurisdiction over the unlawful detainer cases. Whether the respondent has the better right of possession over the subject property. Whether the unregistered Deed of Sale and subsequent transfer of title should be given precedence over the registered title of the decedent.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the petitioners' possession was by mere tolerance, which ripened into unlawful withholding upon demand to vacate, thus establishing a cause of action for unlawful detainer and conferring jurisdiction on the MeTC. The Court also ruled that the respondent, as administratrix, had the better right of possession based on the registered title of the decedent, and that the unregistered Deed of Sale, due to its circumstances and delay in registration, did not prevail over the registered title for purposes of determining possession in an ejectment case.
Ratio Decidendi
On the existence of a cause of action for unlawful detainer and MeTC jurisdiction: The Court reiterated that the allegations in the complaint and the relief sought determine the nature of the action and jurisdiction. It clarified that unlawful detainer arises when possession was initially lawful but ceased to be so upon expiration of the right to possess. The Court found that the respondent's allegations of being the administratrix, the property being part of the estate, demand letters to vacate, and petitioners' refusal sufficiently established unlawful withholding, conferring jurisdiction on the MeTC as the suit was filed within the one-year prescriptive period. The Court cited Rosanna B. Barba v. Court of Appeals to support the proposition that a simple allegation of unlawful withholding is sufficient, and that refusal to vacate after demand letters amounts to such. On the better right of possession: The Court held that petitioners were asking for a re-assessment of factual findings, which is generally not allowed in a petition for review on certiorari. It affirmed the lower courts' finding that petitioners' possession was by mere tolerance. The Court emphasized that a person occupying another's land by tolerance is bound to vacate upon demand, and failure to do so makes their possession unlawful, justifying ejectment. The Court found that the petitioners' possession was by mere tolerance of the decedent, and upon demand by the administratrix, their continued occupancy became unlawful. On the precedence of the unregistered Deed of Sale: The Court agreed with the lower courts that the registered title of the decedent, TCT No. 100777, should take precedence over the unregistered Deed of Sale dated March 30, 1987. The Court noted several circumstances casting doubt on the Deed of Sale's veracity, including its unregistered status during the decedent's lifetime, the alleged vendees not taking possession of their designated units, lack of evidence of realty tax payments, and the significant delay of thirteen years before causing the transfer of title. The Court also pointed out that petitioners occupied units different from those conveyed to their assignors. Therefore, the Court found no error in giving more probative weight to the TCT in the decedent's name over the contested unregistered Deed of Sale for the purpose of determining the better right of possession in the ejectment case.
Main Doctrine
Possession by mere tolerance, upon demand to vacate, ripens into unlawful withholding, giving rise to a cause of action for unlawful detainer, and conferring jurisdiction upon the Metropolitan Trial Courts, irrespective of the pendency of a separate action for annulment of title, provided the ejectment suit is filed within the one-year prescriptive period.