Leonin v. Leonin
REITERATIONFacts
The Antecedents: Petitioners, Evangeline and Pepito Leonin, occupied Apartment C of a property co-owned by Prospero Leonin and five others, including petitioners' father, Teofilo Leonin. Their occupation was by mere tolerance, without paying rent. The property was mortgaged to GSIS, foreclosed, and then redeemed by Teofilo Leonin. Teofilo subsequently sold the property to his daughter, respondent Germaine Leonin, for P48,000.00, and a new title (TCT No. 95939) was issued in her name. After Teofilo's death, Germaine demanded that petitioners vacate the premises, first by letter requesting a lease contract, and later by a demand to vacate within 30 days, threatening legal action. Petitioners did not comply. Procedural History: Prospero Leonin, et al. filed a complaint with the RTC for annulment of the deed of sale, claiming it was simulated and for a false consideration. During the pendency of the annulment case, Germaine Leonin filed an unlawful detainer complaint against petitioners with the MeTC. Petitioners contended that the MeTC lacked jurisdiction, arguing their possession was de jure, more than one year had passed since the demand to vacate, and the annulment case abated the ejectment suit. The RTC, in the annulment case, nullified the deed of sale and ordered Germaine to deliver possession. However, the MeTC ruled in favor of Germaine in the unlawful detainer case. Petitioners appealed to the RTC, which affirmed the MeTC decision. The Court of Appeals also affirmed, holding that the MeTC had jurisdiction as the complaint was filed within one year from the last demand, Germaine acquired title entitling her to possession, and the annulment case did not deprive the MeTC of jurisdiction. The Petition: Petitioners filed a petition with the Supreme Court, faulting the Court of Appeals for sustaining the MeTC and RTC decisions, arguing that their entry into the property was not through the means provided under Section 1, Rule 70 of the Rules of Civil Procedure, that the courts lacked jurisdiction as there was no lease contract, that Germaine did not acquire possession upon the execution of the sale and title, and that the ejectment case should have been suspended pending resolution of the ownership case.
Issue(s)
Whether the Metropolitan Trial Court (MeTC) had jurisdiction over the unlawful detainer case. Whether respondent Germaine Leonin acquired the right to possess the property upon the execution of a deed of absolute sale and the issuance of a transfer certificate of title in her favor. Whether the pendency of the annulment case abated the unlawful detainer case.
Ruling
The petition is denied for lack of merit. The Court affirmed the decision of the Court of Appeals, upholding the jurisdiction of the MeTC over the unlawful detainer case and respondent's right to possess the property.
Ratio Decidendi
On the jurisdiction of the MeTC: The Court held that the MeTC had jurisdiction over the unlawful detainer case. Contrary to petitioners' contention, the complaint sufficiently alleged facts constitutive of unlawful detainer, specifically that respondent is the registered owner and petitioners, occupying by mere tolerance, refused to vacate despite notice. The one-year period for filing an unlawful detainer complaint is reckoned from the date of the last demand, which was October 24, 1996. Since the complaint was filed on February 25, 1997, it was well within the one-year reglementary period. The Court reiterated that the lessor has the right to waive previous demands and allow the lessee to remain in the premises, making the last demand the operative date for the cause of action. On respondent's right to possess: The Court affirmed that respondent Germaine Leonin had the right to possess the property upon the execution of the deed of absolute sale and the issuance of the transfer certificate of title in her name. Petitioners' occupation was on the mere tolerance of the former owners. When they refused to heed respondent's demand to vacate, they became deforciant occupants, thereby entitling the new owner to recover possession. The title issued to respondent served as sufficient basis for her claim to possession against those occupying by mere tolerance. On the abatement of the ejectment case by the annulment case: The Court reiterated the established principle that a pending action for the declaration of nullity of a deed of sale and title does not abate an ejectment case. Ejectment cases are summary in nature and are designed to provide a speedy disposition of the issue of physical possession, independent of the question of ownership. Therefore, the pendency of the annulment case before the RTC and its subsequent appeal to the Court of Appeals did not deprive the MeTC of its jurisdiction over the unlawful detainer case.
Main Doctrine
The pendency of an action for annulment of a deed of sale and title does not abate an ejectment case, and the Metropolitan Trial Court has jurisdiction over an unlawful detainer case filed within one year from the last demand to vacate, even in the absence of a lease contract, where possession is by mere tolerance.