GR 241701; (September, 2020) (Digest)
G.R. No. 241701 , September 16, 2020
MR. & MRS. JOSE ALCANTARA, ET AL., PETITIONERS, VS. DELIA DUMACON-HASSAN, ET AL., REPRESENTED BY DELIA DUMACON-HASSAN AS ADMINISTRATOR AND ATTORNEY-IN-FACT, RESPONDENTS.
FACTS
The respondents are the registered owners of a parcel of land in Kidapawan City. The petitioners are actual occupants of the property, classified into two groups. Group A petitioners were alleged to be squatters occupying the land by mere tolerance. Group B petitioners were lessees on a month-to-month basis who had failed to pay their rent. After repeated demands to vacate proved futile and barangay conciliation failed, the respondents filed a complaint for unlawful detainer before the Municipal Trial Court in Cities (MTCC).
The MTCC ruled in favor of the respondents, ordering all petitioners to vacate. On appeal, the Regional Trial Court (RTC) reversed the decision, dismissing the complaint for lack of jurisdiction. The RTC held that the action was one for accion publiciana, not unlawful detainer, as the issue involved the right of possession, not merely the manner of withholding it. The Court of Appeals (CA) subsequently reversed the RTC and reinstated the MTCC’s decision, prompting the petitioners to elevate the case to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in ruling that the MTCC had jurisdiction over the complaint as an action for unlawful detainer.
RULING
The Supreme Court denied the petition and affirmed the CA’s decision, upholding the MTCC’s jurisdiction over the unlawful detainer case. The Court clarified that unlawful detainer is an action to recover possession from a defendant whose possession was initially lawful but became unlawful upon the expiration of his right to possess. This foundation of lawful possession is derived from contract, either express or implied.
For Group A petitioners, their possession by mere tolerance is considered akin to an implied lease. Their right to possess was derived from the respondents’ permission, and their continued stay after a demand to vacate converted their possession into an unlawful one. For Group B petitioners, their possession was expressly based on a month-to-month lease agreement. Their failure to pay rent constituted a violation of the lease terms, rendering their continued possession unlawful upon the respondents’ demand. The one-year period for filing an unlawful detainer case is reckoned from the date of the final demand to vacate. The respondents complied with this period, and the prior barangay conciliation was a sufficient demand that made the petitioners’ possession unlawful. Therefore, the MTCC correctly exercised jurisdiction over the summary action for ejectment.