Mark Anthony Esteban (In Substitution of the Deceased Gabriel O. Esteban) v. Spouses Rodrigo C. Marcelo

Summary

This case involves an unlawful detainer dispute where tenant-spouses stopped paying rent in 2001 but were not sued until 2005. The Court of Appeals reversed lower court ejectment orders, ruling the case should have been filed as accion publiciana in RTC rather than accion interdictal in MeTC due to the time lapse, and that tenants were protected by urban land reform laws. The Supreme Court reversed, holding that the one-year prescriptive period for unlawful detainer runs from the last demand to vacate (2005), not from non-payment (2001). The Court clarified that both demand to pay and demand to vacate are required before possession becomes unlawful. P.D. 1517 protection was inapplicable absent proof the land was in a declared urban land reform zone. The case establishes important precedents on unlawful detainer prescription periods and urban land reform law coverage.