Heirs of Albina G. Ampil v. Teresa Manahan

Summary

This unlawful detainer case involves a dispute over two residential lots in Paombong, Bulacan between the heirs of Albina G. Ampil and the Manahan family. The heirs claimed their mother owned the properties and allowed the Manahans to occupy them by tolerance. After Albina's death in 1986, the heirs demanded vacation but the Manahans refused, claiming ownership through possession since time immemorial. The Municipal Trial Court and Regional Trial Court ruled for the heirs based on tax declarations and other evidence showing Albina's ownership. The Court of Appeals reversed, finding tax declarations insufficient. The Supreme Court ultimately reinstated the lower courts' decision, holding that while tax declarations are not conclusive proof of ownership, they constitute evidence of title claim when supported by other proof. The Court found the Manahans' occupation was by mere tolerance, supported by Perfecto Manahan's own admission in a sworn statement. The decision clarifies that co-owners may bring ejectment actions under Article 487 of the Civil Code without joining all other co-owners.