Apundar v. Andrin
REITERATIONFacts
The Antecedents: Plaintiff Hugo Apundar instituted an action for forcible entry and unlawful detainer against defendants Dalmacio Andrin and Flaviana Pilapil to recover possession of a parcel of land. Apundar alleged that he had been in peaceful and undisputed possession since 1889, but on February 15, 1915, the defendants forcibly entered, excluded him, and damaged his tobacco plants. Procedural History: The case was initially filed in the justice of the peace court and appealed to the Court of First Instance, which rendered judgment absolving the defendants. The plaintiff appealed to the Supreme Court. The Petition: The plaintiff appealed the decision of the Court of First Instance, arguing that even if the facts were as found, the trial court erred in applying the law, particularly concerning the relationship between the parties.
Issue(s)
Whether the plaintiff established prior possession sufficient to maintain an action for forcible entry and unlawful detainer. Whether the plaintiff's denial of the defendants' title constituted a forfeiture of any right to possess the land, even if a landlord-tenant relationship existed.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance, absolving the defendants from the complaint. The Court held that the plaintiff failed to establish prior possession and that his denial of the defendants' title constituted a forfeiture of any right to occupy the land.
Ratio Decidendi
On the issue of prior possession: The Court found that the plaintiff's claim of continuous possession as owner since 1889 was unsubstantiated. Evidence indicated that the land was included in a possessory information obtained by Bonifacio Magdadaro in 1895, who later sold it to Mercido Andrin. The defendants, as successors in interest, permitted the plaintiff to enter and cultivate the land as a cropper on shares in 1911. As a cropper, the plaintiff did not acquire legal possession of the premises beyond that of an employee; the legal possession remained with the owner. Therefore, for default of prior possession, the plaintiff's action must fail. On the issue of denial of title and forfeiture: Even assuming a landlord-tenant relationship existed, the plaintiff's act in 1915 of denying the defendants' title and asserting ownership in himself operated as a renunciation of his rights under the contract and a forfeiture of the lease. This entitled the owner to reenter peacefully and resume possession. Citing Medel vs. Militante, the Court held that when a tenant denies his landlord's title, the landlord has a right of action to recover immediate possession. If the landlord acquires possession peacefully, as in this case by reentry, the tenant cannot maintain an action to eject the landlord. This prevents circuity of action and recognizes the landlord's affirmative right of action as a defense.
Main Doctrine
In an action for forcible entry and unlawful detainer, a plaintiff claiming prior possession as a cropper on shares must fail if prior possession is not established. Furthermore, even if a landlord-tenant relationship existed, a tenant's denial of the landlord's title operates as a forfeiture of the lease, entitling the landlord to reenter and resume possession, thereby barring the tenant's action.