Pastor Jose Sy v. Spouses Franklin A. Antonio

Summary

This unlawful detainer case involved a dispute over a 355-square meter lot in the NHA's Sapang Palay Resettlement Project. Respondent spouses, as qualified NHA beneficiaries since 1984, allowed petitioner Pastor Jose Sy and his Christian ministry to use their lot for church activities in 1992, subject to vacation upon demand. When respondents needed the property for their children in 2012 and petitioners refused to leave, claiming ownership through a 1992 Deed of Donation and 1997 Deed of Absolute Sale, respondents filed for unlawful detainer. The Supreme Court affirmed the lower courts' unanimous finding that respondents have superior right to possession. Both documents relied upon by petitioners were declared void - the Deed of Donation for lack of proper acceptance and involving future property, and the Deed of Absolute Sale for violating RA 6026's prohibition on transfers within five years of final payment. The Court emphasized that ejectment proceedings determine only physical possession, not ownership, and that the ruling preserves the public policy underlying housing laws for displaced families.