In ejectment cases between squatters, courts must resolve the issue of physical possession to prevent breaches of peace. The Supreme Court clarified that even if neither party has title, the one with prior possession is entitled to remain on the property until someone with a better right lawfully ejects them. This ruling underscores the importance of maintaining order and preventing violence, even in disputes involving illegally occupied land, and it protects the person with priority. It also means squatters can be evicted only through lawful means, like court actions, ensuring order and respect for prior possession.

Between Squatters: Who Gets to Stay? Prior Possession Prevails

The case of Colito T. Pajuyo v. Court of Appeals and Eddie Guevarra stemmed from a dispute over a lot in Quezon City. Colito Pajuyo, after acquiring rights to a 250-square meter lot in 1979 and constructing a house on it, allowed Eddie Guevarra to live there under a Kasunduan (agreement). Guevarra was permitted to stay without rent, provided he maintained the cleanliness and orderliness of the property and agreed to vacate upon demand. When Pajuyo needed the property back in 1994, Guevarra refused to leave, leading to an ejectment case. This scenario raises the central legal question: In a dispute between two parties without legal ownership of the land, who has the right to possess the property? What factors should the courts consider in such a situation?

The Metropolitan Trial Court (MTC) ruled in favor of Pajuyo, stating that the agreement established a landlord-tenant relationship, obligating Guevarra to return possession upon demand. The Regional Trial Court (RTC) affirmed this decision, focusing on the Kasunduan as the basis for the possessory rights. However, the Court of Appeals reversed these decisions, declaring both Pajuyo and Guevarra as squatters on government-owned land, and applying the principle of pari delicto, meaning the court would leave them as they are due to their equal fault. The Court of Appeals also noted that Guevarra had a better right under Proclamation No. 137, which prioritized actual occupants for socialized housing projects.

Disagreeing with the Court of Appeals, the Supreme Court emphasized that the core issue in ejectment cases is physical possession, regardless of ownership. The Court asserted that even in cases where neither party has a valid title, courts have the authority to resolve the issue of who has the right to physical possession. Ownership, or the lack thereof, does not prevent courts from determining who is entitled to possess the property. This authority ensures that disputes are settled peacefully through the legal system, preventing breaches of the peace and maintaining social order. In the words of the Supreme Court in Pitargue v. Sorilla,

“The question that is before this Court is: Are courts without jurisdiction to take cognizance of possessory actions involving these public lands before final award is made by the Lands Department, and before title is given any of the conflicting claimants?”

The Supreme Court dismissed the applicability of the pari delicto principle in ejectment cases. Applying it would encourage lawlessness, allowing squatters to forcibly displace one another, knowing the courts would not intervene. Such an application would undermine the purpose of ejectment suits, which is to prevent violence and compel parties to seek legal recourse. Even if both parties are squatters, the courts must resolve the issue of possession to maintain order and prevent chaos. The ruling underscores that possession is a critical factor that courts must consider to ensure social order, regardless of the parties’ legal standing regarding ownership.

The Supreme Court also disagreed with the Court of Appeals’ consideration of Proclamation No. 137 in determining preferential rights to socialized housing. It stated that the Court of Appeals’ ruling lacked factual and legal basis since Guevarra had failed to prove that the lot was part of a relocation site, that Guevarra actually complied with all the requirements to become a beneficiary, and also, the agency to decide would be the government, and the courts must not pre-empt the government’s decision. Ultimately, the Supreme Court found that Pajuyo had prior possession of the lot and the house. Guevarra’s occupancy was based on the Kasunduan, which obligated him to vacate upon demand. Guevarra’s refusal to vacate constituted unlawful detainer, entitling Pajuyo to regain possession. This part of the ruling validates contract even with squatters in the discussion, since Guevarra willingly entered in it, he is obliged to it’s terms.

FAQs

What was the key issue in this case?	The central issue was determining who had the right to physical possession of a property when both parties were squatters without legal ownership.
What is the principle of pari delicto?	The principle of pari delicto states that the law will not aid either party to an illegal agreement, leaving them where it finds them. However, this principle is not absolute and has exceptions, particularly when it violates public policy.
Why did the Supreme Court reject the application of pari delicto in this case?	The Court rejected its application because it would encourage lawlessness among squatters, who might resort to violence to settle disputes over possession if courts refused to intervene.
What is the significance of prior possession in ejectment cases?	Prior possession is a critical factor. The party who can prove prior possession is entitled to remain on the property until someone with a better right lawfully ejects them.
What is unlawful detainer?	Unlawful detainer occurs when a person withholds possession of real property from another after the expiration or termination of their right to possess it under a contract, express or implied.
How did the Kasunduan affect the outcome of the case?	The Kasunduan established that Guevarra’s occupancy was based on Pajuyo’s permission, which could be withdrawn at any time. Guevarra’s refusal to vacate upon demand constituted unlawful detainer.
Was Proclamation No. 137 relevant to the Supreme Court’s decision?	The Supreme Court found that the Court of Appeals’ reliance on Proclamation No. 137 was premature, as it was more of an issue for a government’s agency. The agency still has to determine who are more qualified for government support.
What was the final ruling of the Supreme Court?	The Supreme Court ruled in favor of Pajuyo, granting him the right to physical possession based on his prior possession and Guevarra’s violation of the Kasunduan.

In conclusion, the Supreme Court’s decision in Pajuyo v. Guevarra reinforces the principle that maintaining social order and preventing violence are paramount, even in disputes involving squatters. Prior possession is a critical factor in determining who has the right to possess a property, ensuring that disputes are resolved peacefully through the legal system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: COLITO T. PAJUYO, VS. COURT OF APPEALS AND EDDIE GUEVARRA, G.R. No. 146364, June 03, 2004