Marcelito D. Quevada v. Court of Appeals

Summary

This case involves an unlawful detainer action by lessor Villaverde against lessee Quevada who refused to vacate leased premises after lease expiration in April 1996. Quevada continued possession without payment despite demands and barangay conciliation. The Supreme Court upheld the ejectment order, ruling that the action was properly filed within the one-year prescriptive period and that Villaverde could bring the action despite not being the titled owner. However, the Court granted partial relief to Quevada by ordering assessment of the house value he built to be offset against unpaid rentals, applying principles of equity and unjust enrichment. The Court rejected Quevada's claim of implied trust regarding the land purchase. The case clarifies important principles on unlawful detainer proceedings, including jurisdictional requirements, prescriptive periods during barangay conciliation, and rights of builders in good faith under Article 448 of the Civil Code.