G.R. No. 126638 - Barba vs. Court of Appeals

Petitioner Rosanna B. Barba filed a complaint for ejectment over a parcel of land with a five-door apartment building in Lagundi, Mexico, Pampanga.
The subject property was originally covered by Transfer Certificate of Title (TCT) No. 257427-R, registered in private respondent Teodora Garcia’s name.
Teodora Garcia allegedly obtained a loan from petitioner amounting to P36,000.00, securing it by mortgaging the property.
Upon Teodora’s failure to repay the loan when due, petitioner foreclosed the mortgage, and the property was sold at public auction where she emerged as the highest bidder.
After the one-year redemption period lapsed, TCT No. 257427-R was cancelled and a new title (TCT No. 353973-R) was issued in petitioner’s name on May 27, 1993.

On September 1, 1993, petitioner, through counsel, sent demand letters to the respondents, commanding them to vacate the premises within fifteen days and asserting a monthly rental charge of P450.00 effective from April 1, 1993.
Despite the notice, private respondents continued occupying the property, prompting petitioner to initiate an ejectment action before the Municipal Circuit Trial Court of Mexico, Pampanga.

Private respondents (except Teodora Garcia) contended that Sevilla Garcia was the true owner of the subject property.
It was alleged that in 1975, the spouses Afrocinia Mago and Delfin Velasquez sold the property to Alfonso Gutierrez and Sevilla Garcia, with Gutierrez later transferring his share to Sevilla Garcia via a notarized deed of sale.
Sevilla Garcia, having left for Cyprus, entrusted the deed and the original title to her mother, Dolores Garcia, who resided on the property until her death in 1984.
After Dolores Garcia’s demise, Teodora Garcia took possession of the certificate of title and deed of sale.
Subsequently, Teodora Garcia conspired with Lourdes Mendoza and her husband by executing a falsified deed of sale—purportedly showing the spouses Velasquez as sellers—to transfer the title to her name.

The Municipal Circuit Trial Court initially ruled in petitioner’s favor on April 5, 1994, ordering respondents to vacate the premises and pay rental and attorney’s fees.
The Regional Trial Court (RTC) of San Fernando, Pampanga reversed the MCTC decision, dismissing the ejectment case for lack of jurisdiction on the ground that the complaint failed to allege prior possession by petitioner.
Later, on October 31, 1995, the Court of Appeals affirmed the RTC decision; however, its basis differed by holding that a genuine issue of ownership interlaced with possession precluded jurisdiction of the lower court to decide the matter.
Petitioner raised several errors with the appellate decision, particularly contesting the reliance on ownership issues and the improper dismissal of her ejectment action.

Initially dismissed by the Supreme Court for the untimely filing of a memorandum, the resolution and entry of judgment were set aside on July 5, 1999, in the interest of justice, reinstating petitioner’s petition for review.
Ultimately, the Supreme Court granted the petition, reversed the Court of Appeals’ decision, and reinstated the ejectment ruling of the Municipal Circuit Trial Court.

Whether the Municipal Circuit Trial Court had jurisdiction over an ejectment (unlawful detainer) case despite the complaint’s alleged failure to specifically assert prior possession by petitioner.
Whether the existence of a genuine issue of ownership, as raised by private respondents, should preclude the court from deciding the issue of possession.

Whether petitioner’s complaint, which alleged her ownership through a foreclosed sale and the issuance of a new TCT (No. 353973-R), sufficiently established a cause of action for unlawful detainer.
Whether the language used in the complaint, though not explicitly utilizing the phrase “unlawfully withholding,” effectively pleaded an actionable infringement on petitioner’s right to possession.

Whether the issue of possession in an ejectment case may be determined independently of the underlying ownership dispute.
Whether adjudicating possession in such cases by the lower courts runs afoul of constitutional or procedural requirements, given the simultaneous civil actions for annulment and reconveyance of title pending against petitioner.

Whether the existence of separate actions for annulment of deed, reconveyance, and even a criminal case regarding alleged falsification affects the jurisdiction of the lower court over the ejectment case.