GR 176055; (March, 2014) (Digest)
G.R. No. 176055 March 17, 2014
SPOUSES EDMUNDO DELA CRUZ and AMELIA CONCIO-DELA CRUZ, Petitioners, vs. SPOUSES RUFINO R. CAPCO AND MARTY C. CAPCO, Respondents.
FACTS
Petitioners Spouses Edmundo Dela Cruz and Amelia Concio-Dela Cruz filed a Complaint for Unlawful Detainer against respondents Spouses Rufino R. Capco and Marty C. Capco before the Metropolitan Trial Court (MeTC) of Pateros. They alleged that the subject land was owned by Amelia’s mother, Teodora T. Concio, by virtue of a Decision in a land registration case, and was registered under TCT No. 31873. The Spouses Capco’s occupation was by mere tolerance of Teodora out of neighborliness and blood relationship. Upon Teodora’s death, the property was conveyed to the Spouses Dela Cruz via an Extra-Judicial Settlement. Demands to vacate were made as the Spouses Dela Cruz intended to use the property, but the Spouses Capco refused. The Spouses Capco claimed a right to occupy the land as Rufino is an heir of its true owner, having established their business and built their house there since 1947. The MeTC ruled in favor of the Spouses Dela Cruz, finding the Spouses Capco’s possession was by tolerance. The Regional Trial Court (RTC) affirmed the MeTC decision. The Court of Appeals (CA) reversed, dismissing the complaint. The CA found the complaint defective for failing to allege how the Spouses Capco’s dispossession started, and noted a need to physically determine the exact boundaries of the land, which is not proper in a summary ejectment proceeding.
ISSUE
Whether the Court of Appeals erred in dismissing the Complaint for Unlawful Detainer.
RULING
The Supreme Court granted the Petition, reversed the Court of Appeals Decision, and reinstated the MeTC and RTC Decisions. The Court held that the allegations in the Complaint were sufficient to confer jurisdiction on the MeTC over the unlawful detainer case. The Complaint explicitly stated that the defendants’ possession was by mere tolerance of the owner, and that such possession became unlawful upon demand to vacate. The Court also found that the identity of the property was sufficiently established through the technical description in TCT No. 31873 and the Spouses Capco’s own judicial admissions during pre-trial, where they admitted their house was situated on the land covered by the said title. The Court ruled that the issue of physical identity or overlapping claims was not raised before the MeTC and was a factual matter not proper for review in a Petition for Review on Certiorari. The Spouses Dela Cruz, as registered owners, had a better right to possession, and the Spouses Capco’s possession, initially lawful as heirs of a prior claimant, became unlawful after the land registration court awarded the property to Teodora Concio. Their continued stay was by mere tolerance.