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### Facts:
– **October 12, 2012**: The respondents Erlinda and Arturo Ventanilla filed a complaint for unlawful detainer against Fortunato Anzures in the Municipal Trial Court (MTC) of Bulacan.
– **Allegations of Respondents**:
– They owned a residential house in Barangay Sta. Ines, Bulakan, Bulacan.
– Ownership was evidenced by tax declarations for 2012 and covered by Original Certificate of Title (OCT) No. 2011000008 under the names of petitioner Fortunato Anzures and his wife, Carolina.
– They asserted that in a Deed of Donation dated March 21, 2011, a 144-square-meter portion of land was donated to them by the Anzures.
– They claimed that Fortunato’s occupation was tolerated and demanded he vacate the property to facilitate its subdivision.
– **Petitioner’s Answer**:
– Claimed ownership of the residential house and the 289-square-meter land.
– Presented a document, “Pagpapamana sa Labas ng Hukuman na may Pagtalikod sa Bahagi ng Lupa at Bilihang Tuluyan sa Lupa,” asserting that he purchased the land from Erlinda for P150,000 on August 2, 2000.
– Challenged the authenticity of the Deed of Donation citing Carolina’s ill health at its execution and denied knowledge or signing the document.
– **MTC Ruling (August 16, 2013)**:
– Ruled in favor of the respondents; ordered petitioner to vacate the property and pay P1,000 per month from the filing of the complaint until vacated, plus attorney’s fees.
– **RTC Ruling (June 30, 2014)**:
– Affirmed MTC’s decision stating respondents had a better right over the property.
– **CA Ruling (July 24, 2015)**:
– Denied petitioner’s appeal, affirming the trial courts’ decisions; ruled allegations in respondents’ complaint made a case for unlawful detainer and the claim of forgery was unsubstantiated.
– **Petition to the Supreme Court**:
– Petitioner contested CA’s upholding of decisions favoring respondents and questioned respondents’ cause of action based on tolerance and the validity of the Deed of Donation.
### Issues:
1. Whether the Court of Appeals gravely erred in upholding the lower courts’ decision that the respondents have a cause of action to eject the petitioner based on tolerance.
2. Whether the Court of Appeals gravely erred in upholding the validity of the Deed of Donation dated March 21, 2011.
### Court’s Decision:
Upon review, the Supreme Court found the petition meritorious. The Supreme Court analyzed key evidence and concluded that both parties were co-owners of the property in dispute. The critical points identified by the Court are as follows:
1. **Ownership and Possession**:
– The evidence supports that the property was originally owned by Vicenta Galvez and subsequently transferred through various documents (Waiver of Rights, Deeds of Absolute Sale) to the sisters Erlinda and Carolina, establishing their co-ownership.
– The donation executed by Carolina on March 21, 2011, donating part of the property to Erlinda, supported continued co-ownership.
– Both parties have rights as co-owners and thus, neither can be ejected without proper partition.
2. **Forgery of the Donation**:
– Petitioner did not present substantial and convincing evidence to prove forgery.
– The court held that self-serving claims do not suffice and upheld the genuineness of the donation document.
3. **Unlawful Detention**:
– Since petitioner, as heir of Carolina, is a recognized co-owner, he enjoys the right to possess and use the property, negating an unlawful detainer claim by respondents.
### Doctrine:
– **Co-ownership**: Co-owners have equal rights to possess, use, and enjoy the property without exclusion until a legal partition is conducted.
– **Burden of Proof for Forgery**: Forgery must be proven by clear, positive, and convincing evidence, not by mere self-serving accusations.
### Class Notes:
– **Unlawful Detention**: Legal action to recover possession from someone who unlawfully withholds possession.
– **Co-ownership**: Defined and governed by Article 494 of the New Civil Code. Rights include:
– Each co-owner may demand partition of property at any time.
– Each co-owner may use the property provided they do not infringe on others’ rights.
– **Forged Documents**: The burden of proof lies on the person alleging, needing clear evidence to substantiate claims.
### Historical Background:
– This case exemplifies the complexity of property ownership and dealings in the Philippines, particularly involving family transactions and informal sales. It illustrates the procedural journey from the trial courts to the Supreme Court, reflecting legal principles of co-ownership and the requirement for clear proof in forgery allegations within the Philippine legal context. This ruling underscores the judiciary’s role in interpreting and reconciling conflicting claims and documents.
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