G.R. No. 48157 - Quiambao vs. Osorio

Private respondents Zenaida Gaza Buensucero, Justina Gaza Bernardo, and Felipe Gaza filed a complaint for forcible entry against petitioner Ricardo Quiambao before the Municipal Court of Malabon, Rizal (Civil Case No. 2526).
Private respondents alleged they were legitimate possessors of a 30,835 sq. m. lot (Lot No. 4, Block 12, Bca 2039, Longos Estate, Barrio Longos, Malabon, Rizal) by virtue of Agreement to Sell No. 3482 issued by the former Land Tenure Administration (now Land Authority, then Department of Agrarian Reform).
Petitioner allegedly entered, placed bamboo posts, and began constructing a house on a 400 sq. m. portion of the lot unlawfully, prompting private respondents to seek ejectment and a preliminary injunction.

Petitioner denied material allegations and stated that the private respondents’ Agreement to Sell had been cancelled by the Land Authority through an order signed by Governor Conrado Estrella.
He raised as an affirmative defense the pendency of Land Authority (L.A.) Case No. 968, an administrative case involving the same parties and subject property, where private respondents’ right of possession was disputed due to default in installment payments.
Petitioner argued that the administrative case was determinative of the ejectment case and thus a prejudicial question barring judicial action until its resolution.

The Municipal Court denied the motion to dismiss based on the affirmative defense and asserted jurisdiction as the case involved physical possession recovery.
Petitioner filed a petition for certiorari with injunction before the Court of First Instance (CFI) of Rizal, Branch XII (Civil Case No. C-1576), praying to enjoin the Municipal Court from proceeding in the ejectment case pending resolution of the administrative case.
The CFI initially issued a restraining order suspending the ejectment case but later dismissed the petition, lifting the restraining order, holding the ejectment case dealt with prior possession and that it had jurisdiction to proceed.
Petitioner and Land Authority (intervenor) filed an appeal with the Court of Appeals, which was later certified to the Supreme Court as involving a pure question of law.

Whether the pendency of the administrative case (L.A. Case No. 968) involving the same parties and property constitutes a prejudicial question barring the ejectment case in the Municipal Court.
Whether the ejectment case involves an issue that is dependent on or subordinate to the administrative case regarding the validity of the Agreement to Sell and possession rights over the disputed lot.