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 he would relinquish it when needed. Mendoza occupied one half and, since 1957, rented the other half to petitioner Ricardo Medina, Sr. In 1976, upon the owners’ request to turn over the property, Mendoza vacated only his portion, encouraged Medina to stay, and continued collecting rent. On December 27, 1984, after receiving P10,000.00, Mendoza finally surrendered the house. The heirs then demanded that Medina vacate as an immediate family member urgently needed it. 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 was affirmed by the Regional Trial Court on appeal. Medina then 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 petition is devoid of merit. On the procedural issue, the Court of Appeals correctly dismissed the petition for review for being filed late. Medina claimed he mailed it on the last day, July 14, 1986, but the court’s records showed it was personally filed on July 15, 1986, past the deadline. Against the conclusive evidence of personal filing stamped on the petition, Medina’s postmaster certification was insufficient, especially without a registry return card. Thus, the appellate court lost jurisdiction as the RTC decision had become final.
On the substantive issue, the MeTC properly exercised jurisdiction. An unlawful detainer action must be filed within one year from the date of last demand. The heirs’ cause of action accrued on January 31, 1985, when Medina refused to vacate after direct demand. The complaint filed on May 16, 1985, was well within the one-year period. Medina’s argument that his 28-year occupancy converted the case into an accion publiciana is erroneous. The duration of possession is irrelevant; the controlling factor is the timeliness of the suit. Since it was filed within one year from the unlawful withholding, it remained an unlawful detainer case within the MeTC’s exclusive original jurisdiction. Medina’s claim for a one-year extension, based on his long occupancy and payment of rent to Mendoza, also fails. The heirs, as owners, were not parties to any lease agreement with Medina and were not bound by his arrangements with Mendoza. Their right to possess the property is paramount.