Facts:

In the case of Romeo Asis, Oscar Asis, and Eduardo Asis vs. Consuelo Asis Vda. de Guevarra, noted as G.R. No. 167554 and decided on February 26, 2008, the petitioners, who are siblings, were involved in multiple ejectment cases initiated by their sister, the respondent Consuelo Asis. The conflict centers around the ownership of apartment units located at 1495, 1497, and 1499 7th Street, Fabie Subdivision, Paco, Manila. Respondent Consuelo claimed exclusive ownership of the units, although she acknowledged that the land was co-owned with her siblings. She alleged that while petitioners had occupied the units as lessees, they stopped paying their monthly rents of P500.00, P1,000.00, and P2,000.00, and despite repeated demands for payment, they refused to comply. The cases were consolidated in the Metropolitan Trial Court (MeTC) of Manila when initial attempts at settlement through the Barangay Lupon failed, leading to a Certification to File Action.

Petitioners contested the claim

...

Facts:

Background of the Case

• Respondent, Consuelo Asis Vda. De Guevarra, claimed ownership of the apartment units located at 1495, 1497, and 1499 7th Street, Fabie Subdivision, Paco, Manila.
• Although the land was held in common by all siblings (including petitioners Romeo, Oscar, and Eduardo Asis), respondent asserted that she was the sole owner of the apartment units because she financed their construction.
• Respondent alleged that the petitioners, despite being co-owners of the land, were merely tenants who paid monthly rentals for the use of the apartments.

Initiation of the Proceedings

• Respondent initiated separate ejectment cases in the Metropolitan Trial Court (MeTC) against her brothers.
• The action for unlawful detainer was grounded on her claim that the petitioners had ceased paying the rent (stated as P500.00, P1,000.00, and P2,000.00 respectively) after a period during which payments were regularly made.
• Prior to filing suit, the dispute was addressed through the Barangay Lupon, and when settlement failed, a Certification to File Action was issued.
• The separate cases were later consolidated due to common issues and questions of fact and law.

Petitioners’ Contentions and Claims

• The petitioners contended that they were co-owners—not only of the lot but also of the apartment units—by virtue of inheritance from their parents, who were the original owners.
• They argued that the inclusion of their names in the title of the property was a voluntary act by the respondent and did not confer exclusive ownership on her.
• The petitioners maintained that the amounts paid to the respondent were not rentals but contributions towards the upkeep and maintenance of the property.
• Specifically, petitioner Eduardo Asis added that any money given was in the form of abuloy (alms), given the respondent’s status as the eldest sibling and a widow without children.

Procedural History and Developments

• The MeTC rendered a judgment in favor of the respondent, ordering the petitioners to vacate the premises and directing the payment of specified rental arrearages along with attorney’s fees and costs.
• On appeal, the Regional Trial Court (RTC) reversed the MeTC decision on the ground that the controversy involved not only possession of the lot but also the rights over the building erected on it, thereby questioning the lower court’s jurisdiction.
• The Court of Appeals (CA) subsequently reinstated the MeTC ruling by holding that the resolution of ownership was permissible only for the purpose of determining the right to possession, not for a definitive adjudication of title.

Key Legal and Factual Issues Raised

• The primary relief sought by the respondent was the restoration of possession through ejectment, even though the dispute briefly touched on issues of title and ownership.
• The petitioners, while invoking the principle of accession and the Chua Peng Hian doctrine, failed to show that the action was primarily aimed at recovering title rather than mere possession.
• The record established that any determination on the matter of ownership by the MeTC was clearly provisional and solely intended to resolve the issue of physical or material possession of the apartment units.

Issue:

Jurisdictional Query

• Whether the Metropolitan Trial Court (MeTC) retains jurisdiction over an ejectment action where the dispute involves both possession of the property and allegations regarding the ownership of the apartment units.

Nature of Determination on Ownership

• Whether the resolution and pronouncement on ownership made by the MeTC—required only for deciding the issue of possession—are provisional in nature and do not preclude further action regarding title determination.

Applicability of Precedents

• Whether the petitioners’ invocation of the Chua Peng Hian doctrine, which concerns the recovery of possession in specific performance actions involving lease contracts, is applicable in the context of an unlawful detainer action.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)