**Sps. Llobrera, et al. vs. Josefina V. Fernandez: A Case on Ejectment and the Boundaries of Tolerance**
### Facts:
This case unfolded in the Philippine legal environment, starting at the Municipal Trial Court in Cities (MTCC), Dagupan City and gradually advancing through the legal hierarchy due to successive appeals by the defendants, culminating in a Supreme Court review.
The root of the dispute was an 1,849 square-meter parcel of land in Dagupan City, titled under Transfer Certificate of Title No. 9042 and co-owned by respondent Josefina V. Fernandez and others. Claiming right through tolerance by one of the co-owners, the petitioners, a group consisting mostly of spouse pairs, resisted vacating the land after a demand letter from Fernandez. Their refusal led Fernandez to file an ejectment complaint at the MTCC after unsuccessful Barangay (village level) conciliation.
Petitioners contended their long-standing occupancy since 1945 granted them rights to the land, citing rental payments to a co-owner’s representative, later consigned to a bank upon refusal of acceptance. Despite these arguments and the loss of rental receipts to a fire, the MTCC ruled in favor of Fernandez, ordering the petitioners’ eviction and payment of dues. This decision was consistently upheld by the Regional Trial Court (RTC) and subsequently by the Court of Appeals (CA), spurring the petitioners to elevate the case to the Supreme Court on several points of error, primarily challenging the basis of their possession and the legal tenability of their consignation (deposit into court) of rental payments.
### Issues:
1. Whether the petitioners’ occupation and possession of the property were based merely on tolerance without a formal contract.
2. If the petitioners’ failure to vacate after demand constitutes valid grounds for their ejectment.
3. The legality of the petitioners’ consignation of rental payments under Article 1256 of the New Civil Code.
4. The legitimacy of the MTCC’s decision ordering the petitioners to pay rental, attorney’s fees, and litigation expenses.
### Court’s Decision:
The Supreme Court affirmed the rulings of the MTCC, RTC, and CA, finding no merit in the petitioner’s arguments. It held that:
1. The absence of a contractual basis for petitioners’ possession meant it was by mere tolerance. The petitioners failed to substantiate their claims of a lease arrangement with credible evidence, rendering their possession precarious upon the owner’s demand for eviction.
2. Given the established premise of possession by tolerance, the demand for vacation by the respondent sufficed as a ground for ejectment.
3. The attempt at consignation of rental payments was deemed legally untenable as it presupposed a debtor-creditor relationship not applicable in this context, where no contractual basis of possession was proven.
4. The awards for payments by the MTCC and their affirmations by higher courts were found justified, considering the petitioners deprived the respondent of property use and unjustifiably refused to relinquish possession.
### Doctrine:
The primary doctrine underscored by the Supreme Court in this case is that possession by mere tolerance of the owner is precarious and revocable at will, granting such owner the right to demand eviction following proper notice. Moreover, it reiterated that consignation requires a demonstrated creditor-debtor relationship, not present in this instance.
### Class Notes:
– **Tolerance-based Possession:** Occupancy without a formal contract, at the landowner’s discretion, is revocable upon demand.
– **Ejectment upon Demand:** Once demand to vacate is made, the tolerated occupant must comply, or face ejectment.
– **Consignation Requirements:** Valid consignation necessitates an undisputed creditor-debtor relationship, proper tender of payment, and, subsequent refusal by the creditor.
– **Damages and Attorney’s Fees:** Courts may award damages, including attorney’s fees and litigation expenses, in ejectment cases if the occupants’ refusal to vacate causes undue harm to the property owner.
### Historical Background:
This case exemplifies the legal process and considerations involved in ejectment cases within the Philippine jurisdiction, highlighting the balance between property rights and the precarious nature of possession by tolerance. It reflects the judiciary’s role in adjudicating land disputes, emphasizing evidence standards and the importance of contractual agreements for securing occupancy rights.
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