**Carmen Cañiza vs. Court of Appeals and Spouses Estrada**
### Facts:
Carmen Cañiza, a 94-year-old retired pharmacist and former professor, was declared incompetent by the RTC of Quezon City due to advanced age and physical infirmities. Amparo A. Evangelista, her niece, was appointed as her legal guardian. Cañiza owned a property in Quezon City where the Estrada spouses lived rent-free out of her kindness. Due to her health and financial needs, Evangelista, on Cañiza’s behalf, sought to eject the Estradas via a suit filed in the MetroTC of Quezon City, which was later amended to include Cañiza as the plaintiff.
The MetroTC ruled in favor of Cañiza, but the decision was reversed by the RTC and subsequently affirmed by the Court of Appeals. The appellate court ruled that an accion publiciana, not an accion interdictal, was the proper remedy. The court also gave credence to a holographic will purportedly bequeathing the property to the Estradas, suggesting their continued occupancy.
### Issues:
1. Whether an ejectment action (desahucio) was the appropriate judicial remedy for the recovery of the property.
2. Whether Evangelista, as Cañiza’s legal guardian, had the authority to initiate the ejectment action.
3. Whether Evangelista could continue representing Cañiza posthumously in the legal proceedings.
### Court’s Decision:
The Supreme Court reversed the decision of the Court of Appeals and reinstated the MetroTC’s decision, ruling in favor of Cañiza. The Court clarified that:
1. An action for unlawful detainer (accion interdictal) was adequately set out in the complaint, based on the Estradas’ occupancy by tolerance, and was the appropriate remedy.
2. Evangelista, as the appointed legal guardian, had full authority to manage Cañiza’s assets, including initiating legal actions for their protection and recovery.
3. The guardianship authority extended to Evangelista allowed her to represent Cañiza’s interests posthumously until the heirs were officially substituted in the proceedings.
### Doctrine:
The Supreme Court elucidated the doctrine that occupancy of property at the owner’s tolerance ceases once the owner demands its return. The mere intention to bequeath property, manifested through an unprobated will, does not grant the beneficiary any present right of possession against the owner’s wishes. Furthermore, the Court reaffirmed that guardians have the authority to manage the ward’s estate, including filing lawsuits to recover property unlawfully withheld.
### Class Notes:
– Unlawful Detainer: Occupancy by tolerance must be vacated upon the owner’s demand, and an action for ejectment is proper.
– Guardianship Rights: A legal guardian has the authority to manage and protect the ward’s property, including initiating legal actions.
– Holographic Will: A will, unless probated, does not confer any rights to the property on the beneficiary.
– Probate Requirement: For wills to affect the disposition of property, they must be duly probated.
### Historical Background:
Carmen Cañiza’s case underscores the challenges surrounding property rights, guardianship, and testamentary intentions in the Philippine legal context. It emphasizes the protective mechanisms available for property owners and the legal standing of guardians in managing the properties of incompetents, setting a precedent for similar future cases.
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