G.R. No. 149498 - Republic vs. Quintero-Hamano

Petitioners, Sps. Jose Dante and Luzviminda Palomar, initiated a forcible entry (ejectment) case against several respondents, including Maria P. Sison, Constancia P. Davantes, Obdulla P. Baculot, and Primitiva P. Tubal.
The dispute arose from the petitioners’ alleged purchase of a residential house and lot located at No. 21 J. Ponce St., Project 4, Quezon City, from Josephine Pacadaljin on January 7, 1987, of which the respondents were in occupation.
The petitioners claimed that after the sale, when Josephine was in the process of moving her belongings, the respondents forcefully entered the premises and, despite demands, refused to vacate, thereby prejudicing the petitioners’ right to possession.

Respondents filed an answer contending that the petitioners were not residents of the subject premises but of No. 23 J. Ponce St.
They alleged that the property was registered in the name of the deceased Loreta Pacadaljin, not in favor of the petitioners, and that the petitioners themselves had forced their way into the premises and removed appliances and furniture.
The respondents further challenged the validity of the sale between the parties, accusing Josephine Pacadaljin of falsifying documents to establish her status and subsequently adjudicate the property in her own favor.

While the forcible entry case was pending in the Metropolitan Trial Court (Branch 35, Quezon City), the respondents filed a separate complaint for annulment of sale and damages in the Regional Trial Court (Branch 78, Quezon City).
In the annulment suit, the respondents maintained that the true registered owner was the deceased Loreta Pacadaljin, asserting their status as surviving relatives. They alleged that Josephine Pacadaljin, by submitting a falsified birth certificate, wrongly assumed ownership and sold the property to the petitioners.
On July 29, 1987, the petitioners moved to dismiss the annulment complaint on the grounds that it did not state a valid cause of action, arguing that it was merely an intra-heir dispute.

During the pendency of the annulment case, the Regional Trial Court issued an order on August 20, 1987, granting a writ of preliminary injunction to stay proceedings in the forcible entry case against a specific judge, effectively affecting the pace of the ejectment trial.
A motion for reconsideration of the preliminary injunction was filed by the petitioners and subsequently dismissed on November 2, 1987, the same day the trial court denied their earlier motion to dismiss.
The petitioners then elevated the matter to the Court of Appeals through a special civil action for certiorari, challenging the adverse orders of the lower courts. The Court of Appeals had earlier dismissed both the special civil action for certiorari and the petitioners’ motion for reconsideration.

The pivotal factual dispute centers on whether the pending annulment of sale case, which involves allegations concerning the validity of the title and ownership, should automatically stay or divest the Municipal Trial Court of its jurisdiction over the forcible entry (ejectment) action.
The matter involves two separate legal questions: one pertaining to the determination of physical possession (ejectment/unlawful detainer) and the other concerning the title or ownership of the property (annulment of sale).

Whether the hearing of an ejectment case in the Municipal Trial Court may be stayed by the pendency of a separately filed annulment of sale case involving the same property.

Whether the distinct subject matters—physical possession in the ejectment case versus title and ownership in the annulment suit—warrant the continuance of the forcible entry proceedings irrespective of the pending title dispute.