CASE DIGEST: Javelosa v. Tapus

 


CECILIA T. JAVELOSA, represented by her Attorney-in-Fact, MA. DIANA J. JIMENEZ, petitioner, vs. EZEQUIEL TAPUS, MARIO MADRIAGA, DANNY M. TAPUZ, JUANITA TAPUS and AURORA MADRIAGA, respondents
G.R. No. 204361          |          July 4, 2018

FACTS:

The petitioner is the registered owner of a parcel of land located at Sitio Pinaungon, Barangay Balabag, Boracay Island, Aklan. The subject property contains an area of 10, 198 sq. m., more or less, and is covered by TCT No. T-35394.

The subject property was occupied by herein respondents. Allegedly, the respondents’ predecessor was assigned as a caretaker of the subject property, and therefore possessed and occupied a portion thereof upon the tolerance and permission of Tirol.

Sometime in 2003, the petitioner’s daughter learned that Expedito Tapus, Jr., a relative of the respondents offered the subject property for sale. Alarmed, Jimenez sought for the possible alternative resolution of the conflict. However, they failed to reach an amicable settlement.

In October 2003, petitioner sent a demand letter to respondents ordering them to vacate the subject property. The demand was unheeded. Thus, prompting the petitioner to file a case for unlawful detainer.

The MCTC awarded the subject property in favor of the petitioner.

The RTC affirmed the ruling of the MCTC. It noted that respondents merely occupied the subject property upon the tolerance of the petitioner. Consequently, they must vacate as soon as the said permission was withdrawn.

The CA reversed the disquisitions of the MCTC and the RTC. The CA pointed out that the petitioner failed to prove the fact that the respondents indeed occupied the subject property through her permission and tolerance. It stressed that to make out a case for unlawful detainer, the petitioner must concomitantly prove that the respondents’ prior lawful possession become unlawful due to the expiration of the right to possess the property. The petitioner failed to show that the respondents occupied the subject property pursuant to her tolerance, and that such permission was present from the very start of their occupation. Absent the fact of tolerance, the remedy of unlawful detainer would be inappropriate.

ISSUE:

Whether or not unlawful detainer is the proper action in this case

RULING:

It is an elementary principle of civil law that the owner of real property is entitled to the possession thereof as an attribute of his or her ownership. In fact, the holder of a Torrens Title is the rightful owner of the property thereby covered is entitled to its possession. This notwithstanding, “the owner cannot simply wrest possession thereof from whoever is in actual occupation of the property.” Rather, to recover possession, the owner must first resort to the proper judicial remedy, and thereafter, satisfy all the conditions necessary for such action to prosper.

Accordingly, the owner may choose among three kinds of actions to recover possession of real property — an accion interdictal, accion publiciana or an accion reivindicatoria.

An accion interdictal is summary in nature, and is cognizable by the proper municipal trial court or metropolitan trial court. It comprises two distinct causes of action, namely, forcible entry (detentacion) and unlawful detainer (desahuico). In forcible entry, one is deprived of the physical possession of real property by means of force, intimidation, strategy, threats, or stealth, whereas in unlawful detainer, one illegally withholds possession after the expiration or termination of his right to hold possession under any contract, express or implied. An action for forcible entry is distinguished from an unlawful detainer case, such that in the former, the possession of the defendant is illegal from the very beginning, whereas in the latter action, the possession of the defendant is originally legal but became illegal due to the expiration or termination of the right to possess. Both actions must be brought within one year from the date of actual entry on the land, in case of forcible entry, and from the date of last demand, in case of unlawful detainer. The only issue in said cases is the right to physical possession.

An accion publiciana is the plenary action to recover the right of possession, which should be brought in the proper regional trial court when dispossession has lasted for more than one year. It is an ordinary civil proceeding to determine the better right of possession of realty independently of title.

An accion reivindicatoria is an action to recover ownership, also brought in the proper RTC in an ordinary civil proceeding.

In the case at bar, the petitioner, claiming to be the owner of the subject property, elected to file an action for unlawful detainer. In making this choice, she bore the correlative burden to sufficiently allege, and thereafter prove by a preponderance of evidence all the jurisdictional facts in the said type of action. Specifically, the petitioner was charged with proving the following jurisdictional facts:

(i)                  Initially, possession of property by the defendant was by contract with or by tolerance of the plaintiff;

(ii)                Eventually, such possession became illegal upon notice by plaintiff to defendant of the termination of the of the latter’s right of possession;

(iii)               Thereafter, the defendant remained in possession of the property and deprived the plaintiff of the enjoyment thereof; and

(iv)               Within 1 year from the last demand on defendant to vacate the property, the plaintiff instituted the complaint for ejectment.

In order for the petitioner to successfully prosecute her case for unlawful detainer, it is imperative upon her to prove all the assertions in her complaint. After all, “the basic rule is that mere allegation is not evidence and is not equivalent to proof.” Unfortunately, the petitioner failed to prove how and when the respondents entered the subject lot, as well as how and when the permission to occupy was purportedly given. In fact, she was conspicuously silent about the details on how the permission to enter was given, save for her bare assertion that the respondents’ occupied the premises as caretakers thereof. The absence of such essential details is especially troubling considering that the respondents have been occupying the subject property for more than 70 years, a fact which was not disputed by the petitioner. In this regard, it is must be shown that the respondents first came into the property due to the permission given by the petitioner or her predecessors.

It cannot be gainsaid that the fact of tolerance is of utmost importance in an action for unlawful detainer. Without proof that the possession was legal at the outset, the logical conclusion would be that the defendant’s possession of the subject property will be deemed illegal from the very beginning, for which, the action for unlawful detainer shall be dismissed.

Remarkably, in Quijano v. Atty. Amante, the Court ruled that in an action for unlawful detainer, the plaintiff must show that the possession was initially lawful, and thereafter, establish the basis of such lawful possession. Similarly, should the plaintiff claim that the respondent’s possession was by his/her tolerance, then such acts of tolerance must be proved. A bare allegation of tolerance will not suffice. At least, the plaintiff must point to the overt acts indicative of his/her or predecessor’s permission to occupy the disputed property. Failing in this regard, the occupant’s possession could then be deemed to have been illegal from the beginning. Consequently, the action for unlawful detainer will fail. Neither may the ejectment suit be treated as one for forcible entry in the absence of averments that the entry in the property had been effected through force, intimidation, threats, strategy or stealth.

Similarly, in Suarez v. Sps. Emboy, the Court warned that “when the complaint fails to aver the facts constitutive of forcible entry or unlawful detainer, as where it does not state how entry was effected or how and when dispossession started, the remedy should either be an accion publiciana or accion reivindicatoria.”

An action for unlawful detainer fails in the absence of proof of tolerance, coupled with evidence of how the entry of the respondents was effected, or how and when the dispossession started. This rule is so stringent such that the Court categorically declared in Go, Jr. v. CA that tolerance cannot be presumed from the owner’s failure to eject the occupants from the land. Rather, “tolerance always carries with it ‘permission’ and not merely silence or inaction for silence or inaction is negligence, not tolerance.” On this score, the petitioner’s tenacious claim that the fact of tolerance may be surmised from her refusal for many years to file an action to evict the respondents is obviously flawed.


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