Ampil v. Manahan
REITERATIONFacts
The Antecedents: This case concerns a dispute over the possession of two adjoining residential lots in Sto. Niño, Paombong, Bulacan. The petitioners, heirs of the late Albina G. Ampil, claim ownership of these lots, identified as Lot No. 1186 and Lot 742. They allege that during Albina's lifetime, she permitted the respondents' predecessor-in-interest, Perfecto Manahan, and his family to occupy a portion of these properties on the condition that they would vacate upon request. After Albina's death in 1986, her heirs requested the Manahan family to leave, but they refused, leading to the initiation of legal proceedings. Procedural History: The dispute was first brought before the Lupong Tagapamayapa, which issued a Certification to File an Action due to the failure to reach a settlement. Subsequently, the heirs of Albina, represented by Exequiel G. Ampil, sent a demand letter to the respondents to surrender possession, which was also unsuccessful. An ejectment complaint was then filed before the Municipal Trial Court (MTC) of Paombong, Bulacan. The MTC ruled in favor of the petitioners, granting them possession and ordering the respondents to pay monthly rentals and attorney's fees. The Regional Trial Court (RTC) affirmed the MTC's decision. However, the Court of Appeals (CA) reversed the RTC's ruling, dismissing the unlawful detainer case, holding that tax declarations alone are insufficient proof of ownership or right to possession. The Petition: The petitioners, the Heirs of Albina G. Ampil, filed a Petition for Review under Rule 45 of the Rules of Court, assailing the CA's decision. They argue that the CA erred in solely relying on tax declarations and in disregarding other evidence, such as a Sinumpaang Salaysay executed by Perfecto Manahan admitting Albina's ownership, and the issuance of Original Certificate of Title No. 13627 in the names of Albina's heirs. The petitioners contend that their claim of ownership and right to possession is supported by a preponderance of evidence, including tax declarations, proof of tax payments, a survey plan, and the aforementioned Sinumpaang Salaysay and title. The respondents, in turn, questioned the authority of Exequiel G. Ampil to file the petition and argued that the petition raises factual issues impermissible under Rule 45.
Issue(s)
Whether Exequiel G. Ampil, as a co-owner, has the authority to file the unlawful detainer case without the special power of attorney from his co-heirs. Whether the Court of Appeals erred in reversing the findings of the MTC and RTC regarding the right to physical possession of the disputed property. Whether the respondents' possession of the property was by mere tolerance.
Ruling
The petition is GRANTED. The Decision and Resolution of the Court of Appeals are REVERSED and SET ASIDE. The Decision of the Municipal Trial Court, affirmed by the Regional Trial Court, is REINSTATED.
Ratio Decidendi
On the authority of Exequiel G. Ampil to file the case: Article 487 of the Civil Code provides that any of the co-owners may bring an action for ejectment without joining the others, as such suit is presumed to be for the benefit of all. This principle extends to all suits for the recovery of possession. In this case, the complaint clearly stated that the disputed property was held in common by the petitioners and that the action was brought to recover possession for the benefit of all the heirs of Albina. Therefore, Exequiel, as a co-owner, was authorized to file the action for unlawful detainer even without a special power of attorney from his co-heirs, as complete relief could be accorded in the suit even without their participation. On the right to physical possession and the weight of evidence: The Court finds merit in the petition and sustains the findings of the MTC and RTC. While petitions for review are generally limited to questions of law, an exception exists when the factual findings of the CA are contrary to those of the trial courts. In an unlawful detainer case, the primary issue is physical possession. However, when ownership is raised, the court may pass upon it to determine the right to possess, though this adjudication is provisional. The bare allegation of respondents regarding their continuous possession since time immemorial cannot prevail over the tax declarations and other documentary evidence presented by petitioners, including proof of tax payments by Albina and a survey plan supporting her land registration application. Furthermore, the issuance of Original Certificate of Title No. P-13627 over Lot 742 in the names of Albina's heirs strengthens petitioners' claim. The respondents failed to present any supporting evidence for their claim, making the petitioners' evidence more probative. On whether the respondents' possession was by mere tolerance: The Court finds that the respondents' occupation of the lot in question was by mere tolerance. This is supported by evidence, including a Sinumpaang Salaysay executed by Perfecto Manahan in a previous criminal case, wherein he admitted that Albina was the owner of the lots and that he was merely allowed to use the property on condition that they would vacate upon demand. The dismissal of the criminal case was based on the finding that their stay was lawful due to Albina's permission, contingent on vacating when needed. The respondents' failure to present proof of open, continuous, and adverse possession since time immemorial, and their failure to declare the lots for taxation purposes, further support the conclusion that their possession was by tolerance, not in the concept of an owner. Ownership cannot be acquired by mere occupation; tax declarations, while not conclusive, are strong evidence of a claim of title.
Main Doctrine
In unlawful detainer cases, while the issue of ownership is not the primary concern, it may be passed upon to determine the right to possess. A co-owner may bring an action for ejectment for the benefit of all co-owners. Tax declarations, while not conclusive proof of ownership, are strong evidence of a claim of title, especially when corroborated by other evidence and the payment of real property taxes.