Title
Bormaheco, Inc. vs. Abanes
Case
G.R. No. L-28087
Decision Date
Jul 13, 1973
Bormaheco sued to eject occupants claiming preferential rights under RA 477; SC ruled municipal court lacked jurisdiction due to title dispute and absence of prior possession.
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Case Digest (G.R. No. L-28087)

Facts:

  1. Acquisition of Land: On June 26, 1964, Bormaheco, Inc. (appellant) acquired a parcel of land in Santa Ana, Manila, from the National Shipyard and Steel Corporation (Nassco).
  2. Occupancy by Defendants: The defendants had been occupying portions of the land since at least 1949, constructing houses under valid contracts with the Alien Property Administration, Nassco's predecessor-in-interest.
  3. Demand to Vacate: Bormaheco informed the defendants of its purchase and demanded they vacate the premises, but the defendants refused, claiming preferential rights under Republic Act No. 477.
  4. Legal Proceedings: Bormaheco filed a complaint for ejectment in the municipal court, which ruled in its favor. However, the Court of First Instance reversed the decision, holding that the municipal court lacked jurisdiction due to the absence of prior physical possession by Bormaheco and the involvement of a title dispute.
  5. Preferential Rights: The defendants argued that, under Republic Act No. 477, they had preferential rights to purchase the land as bona fide occupants since 1946.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction in Ejectment Cases: An ejectment case requires prior physical possession by the plaintiff. Without this, the municipal court lacks jurisdiction.
  2. Title Disputes: When a defendant raises a bona fide claim of title in an ejectment case, the municipal court must dismiss the case, as title disputes fall within the exclusive jurisdiction of the Court of First Instance.
  3. Preferential Rights Under Republic Act No. 477: The defendants' claim of preferential rights to purchase the land under Republic Act No. 477 was a plausible defense, warranting dismissal of the ejectment case.
  4. Social Justice Principle: The Court emphasized that summary proceedings like ejectment are not suitable for resolving disputes involving social justice legislation, such as Republic Act No. 477, which aims to protect bona fide occupants.


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