Refugia v. Court of Appeals

G.R. No. 118284 (July 5, 1996)

Facts:

The case involves a dispute over a parcel of land and a duplex apartment building located at No. 16 Meriales Street, Marulas, Valenzuela, owned by private respondents Arturo Refugia and Aurora Timbang-Refugia, as evidenced by Transfer Certificate of Title No. 218979. The title was issued following a Deed of Absolute Sale executed on September 11, 1975, in favor of Arturo Refugia, although the purchase price of P20,000 was reportedly advanced by his father, petitioner Mamerto Refugia.

After the construction of the duplex in 1976, the petitioners occupied one unit while the respondents occupied the other. Tensions arose between the families, particularly between Feliza Refugia (petitioner) and Aurora Timbang-Refugia (respondent), leading to a demand for the petitioners to vacate their unit in February 1993. The petitioners refused, claiming ownership based on Mamerto's financial contribution to the purchase of the lot.

The matter was brought to the barangay court for conciliation, but no settlement was reached, prompting the private respondents to file an ejectment suit against the petitioners on October 20, 1993, in the Metropolitan Trial Court of Valenzuela. The trial court dismissed the ejectment complaint on March 4, 1994, ruling that the petitioners were lawful occupants based on their claim of co-ownership.

The Regional Trial Court later affirmed this decision with modifications, declaring both parties as co-owners. The private respondents then appealed to the Court of Appeals, which reversed the lower courts' decisions, ordering the petitioners to vacate the premises.

Legal Issues:

1. Whether the Court of Appeals erred in giving due course to the private respondents' appeal despite it being filed beyond the reglementary period.
2. Whether the Regional Trial Court had the authority to resolve the issue of ownership in an ejectment case.
3. Whether the petitioners' claim of co-ownership was supported by sufficient evidence.

Arguments:

• Petitioners' Arguments:

  • The private respondents' appeal was filed late, as they did not adhere to the 15-day reglementary period after receiving the Regional Trial Court's decision.
  • The factual findings of the trial court should not be disturbed on appeal.
  • Their claim of co-ownership was based on Mamerto's financial contribution and a verbal agreement to subdivide the property.
  • The issue of ownership is relevant to the question of possession in an ejectment case.

• Respondents' Arguments:

  • The appeal was timely as the motion for reconsideration filed by the private respondents was valid and did not interrupt the appeal period.
  • The Regional Trial Court overstepped its bounds by addressing ownership, which is not within the scope of an ejectment case.
  • The petitioners' claims of ownership were mere allegations unsupported by concrete evidence, as the title and deed of sale were in the respondents' names.

Court's Decision and Legal Reasoning:

The Court of Appeals ruled that the Regional Trial Court lacked the authority to resolve the issue of ownership in an ejectment case, emphasizing that its jurisdiction was limited to determining possession. The court found that the petitioners' claim of co-ownership was not substantiated by sufficient evidence, particularly given the existence of the title and deed of sale favoring the respondents.

The Court also addressed the procedural issue regarding the timeliness of the appeal, concluding that the private respondents' motion for reconsideration was valid and did not affect the jurisdictional requirements for appeal. The Court of Appeals held that the petitioners were occupying the premises by mere tolerance, which justified the ejectment action.

Significant Legal Principles Established:

1. The jurisdiction of the Regional Trial Court in ejectment cases is limited to issues of possession, and it cannot resolve ownership disputes.
2. The filing of a motion for reconsideration does not interrupt the reglementary period for appeal in cases under the jurisdiction of the Regional Trial Court.
3. A person occupying property by mere tolerance is subject to ejectment upon demand by the owner.