G.R. No. 196529; July 01, 2013
WILLIAM T. GO, PETITIONER, vs. ALBERTO T. LOOYUKO, SUBSTITUTED BY HIS LEGAL HEIRS TERESITA C. LOOYUKO, ALBERTO LOOYUKO, JR., ABRAHAM LOOYUKO AND STEPHANIE LOOYUKO (MINORS, REPRESENTED BY THEIR MOTHER TERESITA LOOYUKO), ALVIN, AMOS, AARON, DAVID, SOLOMON AND NOAH, ALL SURNAMED PADECIO, RESPONDENTS.

FACTS

Respondent Alberto Looyuko and Jimmy Go, brother of petitioner William Go, were partners in Noah’s Ark Group of Companies. William was allowed by Looyuko to occupy a townhouse in Quezon City. In 1998, Looyuko demanded that William vacate the property. Jimmy Go then filed an adverse claim on the title, asserting the property was bought with partnership funds and he was a co-owner. William refused to vacate, relying on his brother’s claim. Looyuko filed an unlawful detainer case before the Metropolitan Trial Court (MeTC), presenting the Transfer Certificate of Title (TCT) in his name. William countered with partnership documents and evidence suggesting the property belonged to Noah’s Ark.
The MeTC ruled for Looyuko, finding him the registered owner entitled to possession. On appeal, the Regional Trial Court (RTC) reversed the MeTC, deferring to a separate civil case for specific performance filed by Jimmy Go to establish co-ownership, and ruled the property was partnership property. The Court of Appeals (CA) reinstated the MeTC decision, holding that the ejectment case could be resolved solely on the issue of possession based on Looyuko’s title, without needing to adjudicate the underlying claim of ownership.

ISSUE

Whether the Court of Appeals erred in ruling that the unlawful detainer case could proceed and be resolved without first settling the issue of ownership raised by the petitioner.

RULING

The Supreme Court denied the petition, affirming the CA. The Court emphasized that a petition for review under Rule 45 is limited to questions of law; William Go’s arguments essentially invited a re-evaluation of evidence, which is a question of fact beyond the Court’s scope of review. On the substantive issue, the Court upheld the CA’s legal logic that an unlawful detainer suit is fundamentally a quieting process focused on physical possession, not title.
The Court explained that in an unlawful detainer case, the plaintiff must prove that his possession was initially lawful, by tolerance or contract, and that such possession was later terminated by an express demand to vacate. Looyuko successfully established these elements by presenting the TCT and the demand letter. The defendant’s claim of a better right, such as co-ownership derived from a partnership, does not divest the inferior court of jurisdiction. Such a claim is a collateral attack on title, which is not permissible in an ejectment proceeding. The proper recourse for William Go is to ventilate the ownership issue in the separate pending civil case for specific performance. The Court also clarified that prior physical possession by the plaintiff is not an indispensable requirement in unlawful detainer; it is sufficient that possession is unlawfully withheld after the termination of a right to hold. Therefore, the ejectment case was correctly decided based on Looyuko’s superior right to possession as the titled owner, without pre-judging the ultimate issue of ownership.