G.R. No. 190143 , August 10, 2016
SPOUSES LOLITA ORENCIA AND PEDRO D. ORENCIA, Petitioners, vs. FELISA CRUS VDA. DE RANIN, represented by her Attorney-in-Fact, Mrs. Estela C. Tanchoco, Respondent

FACTS

Respondent Felisa Crus Vda. de Ranin, represented by her sister, filed a Complaint for Unlawful Detainer with Damages against petitioners Spouses Lolita and Pedro Orencia over Door No. 4 of a seven-door apartment and lot in Taytay, Rizal. The property is registered under the respondent’s name as evidenced by Transfer Certificate of Title (TCT) No. 514491 and Tax Declarations. The respondent alleged that the petitioners stopped paying monthly rentals starting April 15, 2005. A formal demand letter to vacate was sent on April 24, 2006, received by the petitioners’ representative on May 2, 2006, and the matter was referred to barangay conciliation, which failed, resulting in a Certification to File Action. The Municipal Trial Court (MTC) dismissed the complaint, ruling that the respondent lacked cause of action and personality to sue because the evidence suggested the property might belong to a certain “Lea Liza Cruz Ranin,” not the respondent. The Regional Trial Court (RTC) affirmed the MTC decision. The Court of Appeals (CA) reversed the lower courts, holding that the respondent’s TCT sufficiently proved her better right of possession and that the complaint adequately made out a case for unlawful detainer.

ISSUE

Whether the respondent has the right of physical possession of the subject property.

RULING

Yes. The Supreme Court denied the petition and affirmed the CA Decision and Resolution. The Court held that unlawful detainer is an action to recover possession based on the defendant’s unlawful withholding of possession after the expiration or termination of a right to possess (e.g., non-payment of rent). The sole issue is physical possession, independent of ownership claims, though ownership may be resolved if necessary to determine possession. The respondent’s complaint established a case for unlawful detainer by alleging the petitioners’ failure to pay rent and refusal to vacate despite demand. The respondent proved her better right of possession through TCT No. 514491 registered in her name, which prevails over tax declarations. The petitioners’ arguments—including lack of ownership, non-receipt of demand, and absence of prior barangay conciliation—were unmeritorious. The demand letter was duly received per postal certification, and a Certification to File Action from the barangay existed. The respondent, as title holder, is the recognized owner with a better right to possession.