FACTS:

The case involves a parcel of land owned by the Republic of the Philippines and the National Power Corporation, with the Privatization Management Office representing the petitioners. Sunvar Realty Development Corporation occupied the land through expired sublease agreements with the Technology Resource Center Foundation. Despite the expiration of the lease, Sunvar continued to occupy the property. Petitioners sent multiple notices to vacate, but Sunvar refused to comply.

The petitioners filed a complaint for unlawful detainer with the Metropolitan Trial Court, seeking Sunvar's eviction and damages. Sunvar moved to dismiss the complaint, arguing that it should be under the jurisdiction of the Regional Trial Court. The motion to dismiss was denied, and Sunvar filed a Rule 65 petition for certiorari with the RTC. The RTC denied the motion to dismiss and eventually granted Sunvar's petition, dismissing the complaint. Petitioners then filed a Rule 45 petition with the Supreme Court, arguing that their resort to this mode of review was proper.

In their petition, the petitioners raised questions of law regarding the jurisdiction of the RTC to entertain a certiorari petition filed against the interlocutory order of the MeTC in an unlawful detainer suit. They argued that the RTC should have dismissed the certiorari petition filed by Sunvar since the rules prohibit such relief for unfavorable interlocutory orders of the MeTC. The RTC refused to dismiss the certiorari petition and proceeded to hear it on the merits. Sunvar relied on previous cases to justify the filing, but the court found that the circumstances did not justify the prohibited pleading.

ISSUES:

1. Whether the Rule 45 Petition filed by petitioners is proper.

2. Whether the RTC erred in taking cognizance of the Rule 65 Petition filed by respondent Sunvar against the interlocutory order of the MeTC in an unlawful detainer suit.

3. Whether the complaint for unlawful detainer was properly filed within one year from the unlawful deprivation of possession, or if an accion publiciana should have been filed instead.

RULING:

1. The Supreme Court found the Rule 45 Petition proper as it solely raised questions of law.

2. The RTC erred in entertaining the Rule 65 Petition from respondent Sunvar since the Rules on Summary Procedure expressly prohibit filing a certiorari petition against interlocutory orders in summary proceedings.

3. The Supreme Court ruled that the one-year period to file an unlawful detainer case should be counted from the final notice to vacate served on 03 February 2009. Therefore, the complaint filed on 23 July 2009 was within the one-year period allowed for an unlawful detainer suit, making it timely and within the jurisdiction of the MeTC.

PRINCIPLES:

1. Rule 45 Petition in Summary Proceedings:

   • A Rule 45 Petition before the Supreme Court is proper when only questions of law are raised or involved.

2. Summary Procedure Restrictions:

   • Under the Rules on Summary Procedure, a certiorari petition against an interlocutory order issued by the court in a summary proceeding is a prohibited pleading, maintaining the goal of expeditious and inexpensive case determination.

3. Jurisdiction in Unlawful Detainer Cases

   • The one-year period to file an unlawful detainer suit should be reckoned from the date of the last demand to vacate.

   • An action for unlawful detainer must meet specific requisites: initial lawful possession by the defendant, conversion to illegal possession after notice of termination, continued possession after demand to vacate, and filing the suit within one year from the last demand.

4. Reckoning of the One-Year Period:

   • The period for filing an unlawful detainer suit is counted from the last demand to vacate, emphasizing the waiver of an action can be implied by allowing continued occupancy after initial demands. Subsequent demands that serve as mere reminders do not renew this period unless unraised factual determinations suggest otherwise.