G.R. No. 76707 February 6, 1990
RICARDO MEDINA, SR., petitioner, vs. THE HONORABLE COURT OF APPEALS and HEIRS OF LEANDRO IGAMA, respondents.

FACTS

The heirs of Leandro Igama are the registered owners of a residential lot in Pandacan, Manila. In the mid-1950s, Leandro entrusted the property to his brother-in-law, Engr. Teofilo Mendoza, who was permitted to build a duplex house on the condition that it would be relinquished when the owner needed it. Mendoza occupied one half and, since 1957, rented the other half to petitioner Ricardo Medina, Sr. In 1976, upon the owner’s request to vacate, Mendoza only surrendered his own half, continued collecting rent from Medina, and encouraged him to stay. On December 27, 1984, after receiving P10,000.00, Mendoza finally turned over the property. The Igama heirs then demanded that Medina vacate as an immediate family member urgently needed the house. Medina refused.
After failed barangay conciliation, the heirs filed an unlawful detainer case against Medina in the Metropolitan Trial Court (MeTC) of Manila on May 16, 1985. The MeTC ruled for the heirs, ordering Medina to vacate. This decision was affirmed by the Regional Trial Court on appeal. Medina subsequently filed a petition for review with the Court of Appeals.

ISSUE

The primary issues are: (1) whether the Court of Appeals correctly dismissed Medina’s petition for review as filed out of time; and (2) whether the MeTC had jurisdiction over the unlawful detainer case.

RULING

The Supreme Court dismissed the petition, upholding the Court of Appeals’ dismissal on procedural grounds and affirming the MeTC’s jurisdiction. On procedure, Medina claimed he mailed his petition on the last day, July 14, 1986, making it timely. However, the Court found the petition was personally filed with the Court of Appeals on July 15, 1986, as stamped on its face, which was beyond the reglementary period. The evidence of personal delivery, consistent with court records, prevailed over his postal certification. Consequently, the appellate court correctly deemed the petition filed out of time and the RTC decision final.
On the substantive issue of jurisdiction, the Court ruled the action was properly an unlawful detainer within the MeTC’s exclusive original jurisdiction. An unlawful detainer suit must be filed within one year from the date of last demand. Here, the final demand to vacate was made on January 31, 1985, and the complaint was filed on May 16, 1985, well within the one-year period. The cause of action arose from the owner’s termination of Medina’s tolerance, not from a prior lease contract. Medina’s claim of a 28-year occupancy did not convert the action into an accion publiciana, as the filing was timely. Furthermore, as the owners were not privy to any agreement between Medina and Mendoza, they could not be compelled to grant a lease extension. The petition was devoid of merit.