G.R. No. 217111 , March 13, 2023
LILAH GAIL CORPUZ ALFILER, PETITIONER, VS. SPS. JOHN CAYABYAB AND GERALDINE CAYABYAB, REPRESENTED BY ATTORNEY-IN-FACT, JOSE VASALLO, RESPONDENTS.

FACTS

The case involves an ejectment suit over a parcel of land in Quezon City (subject property) originally registered in the name of Quintin Santiago, Jr. In March 1985, Quintin filed a complaint before the Barangay Lupon against Linglingay Corpuz (petitioner’s mother) and others. They entered into an Amicable Settlement on May 1, 1985, agreeing that Linglingay, et al. would purchase the property for P146,000.00, with payments to be completed by August 23, 1985. Partial payments totaling P72,425.00 were allegedly made, the last in June 1986. Quintin died on March 12, 1997. On August 20, 1997, a Deed of Absolute Sale (DOAS) over the subject property was executed by Norman Santiago as attorney-in-fact of Quintin in favor of respondents Spouses Cayabyab. On March 18, 2010, respondents filed a Complaint for Ejectment before the Metropolitan Trial Court (MeTC) against petitioner and others. Respondents claimed ownership via the DOAS and alleged that defendants illegally built houses without paying rent since 1997. Petitioner defended by arguing the DOAS was null and void because Quintin died before its execution, thus any agency was extinguished, and that her possession was based on the prior Amicable Settlement which constituted a contract of sale. She also challenged the MeTC’s jurisdiction, claiming the action was filed more than one year from alleged dispossession. The MeTC ruled for respondents, ordering petitioner to vacate and pay rentals and attorney’s fees. The Regional Trial Court (RTC) affirmed the MeTC Decision. Petitioner filed a Petition for Certiorari under Rule 65 before the Court of Appeals (CA), which dismissed it for being the wrong mode of appeal, stating a Petition for Review under Rule 42 was the proper remedy. Petitioner’s motion for reconsideration was denied.

ISSUE

1. Whether the CA correctly dismissed the Petition for Certiorari for being the wrong mode of appeal.
2. Whether the MeTC had jurisdiction over the ejectment case.
3. Whether the Deed of Absolute Sale dated August 20, 1997 is valid and conferred ownership rights upon respondents.
4. Whether petitioner has a better right to possession based on the 1985 Amicable Settlement.

RULING

1. On the procedural issue: The Supreme Court held that while the CA was technically correct that a Petition for Review under Rule 42 was the proper remedy to assail the RTC Decision, the Court opted to relax procedural rules in the interest of substantial justice. The case presented a compelling reason for liberal application as it involved a review of a potentially void deed affecting property rights, and a strict adherence to procedure would result in a miscarriage of justice. The Court treated the petition as one filed under Rule 45.
2. On jurisdiction: The Supreme Court held that the MeTC had jurisdiction over the ejectment case. The one-year period for filing an ejectment suit is counted from the date of last demand. Respondents’ cause of action accrued upon their demand to vacate on May 8, 2009, and the complaint was filed on March 18, 2010, which was within the one-year period. The allegation of respondents’ dispossession in 1997 was not the reckoning point for the summary action.
3. On the validity of the Deed of Absolute Sale: The Supreme Court declared the DOAS dated August 20, 1997 null and void. The agency of Norman Santiago was extinguished by the death of the principal, Quintin Santiago, Jr., on March 12, 1997, prior to the sale. An agent cannot act on behalf of a deceased principal. The DOAS, executed after Quintin’s death, was invalid and conveyed no rights to respondents. The Court found no evidence that the agency was coupled with an interest or constituted in the interest of a third party to survive the principal’s death.
4. On the right to possession: The Supreme Court ruled that petitioner, deriving her claim from the 1985 Amicable Settlement, did not acquire a better right of possession that would prevail in an ejectment suit. The Amicable Settlement was merely a contract to sell, not a consummated sale, as the full purchase price was not paid. Petitioner’s predecessors-in-interest only made partial payments. Without full payment and the execution of a final deed of sale, ownership remained with Quintin and did not pass to petitioner’s predecessors. In an ejectment case, the issue is possession de facto, not ownership. Respondents, as alleged successors-in-interest to the registered owner (Quintin), had a prima facie right to possess the property as against petitioner, who failed to prove a legal right to possess based on a consummated sale or any other title.
The Court DENIED the petition and AFFIRMED the MeTC and RTC Decisions ordering petitioner to vacate the property. The nullity of the DOAS did not automatically vest possession in petitioner, as she failed to establish a superior right of possession based on the unperfected contract to sell. The ejectment order stood because respondents, claiming under the original owner, had a better right to possess than petitioner, a mere buyer who had not fully paid and whose claim was based on an unperfected contract.