G.R. No. 150025 - Spouses Barnachea vs. Court of Appeals

The case involves petitioners Narciso and Julita Barnachea (now represented by the heirs of the deceased Julita Barnachea) versus respondents Avelino and Priscilla Ignacio.
The dispute arises from an ejectment complaint filed by the respondents before the Municipal Trial Court (MTC) of Pulilan, Bulacan concerning adjacent real properties.
The subject properties include:

Lots titled in the name of respondent Avelino Ignacio – specifically Subdivision Lot 16 (TCT No. 86821) and Subdivision Lot 17 (TCT No. 86822).
The petitioners own and occupy a property derived from land that originally belonged to Purificacion Santos Imperial and was subdivided and transferred among tenant-farmers Santiago Isidro and Procopio de Guzman.

The disputed lots have a complex title history arising from inheritance and subdivision of ancestral land.

Respondents filed the ejectment complaint on October 20, 1998.
The complaint targeted the petitioners’ continued possession and occupation of the property, which had been done with the respondents’ initial tolerance.

Petitioners received summons on April 13, 2000.
Rather than filing a new Answer, they filed a Motion for Extension of Time to File an Answer on April 18, 2000, which was denied by the MTC on May 5, 2000.
A Motion for Reconsideration was subsequently filed on May 23, 2000.
To avert the issuance of a writ of execution (filed by respondents on May 24, 2000 and received by petitioners on May 26, 2000), petitioners filed a Notice of Appeal.

A subpoena set a hearing on the petitioners’ motion for reconsideration and respondents’ motion for issuance of a writ on June 19, 2000.
Petitioners filed a Compliance prayer seeking that the pending resolution and the Notice of Appeal be considered as filed ex abundanti cautela.
Respondents filed a Manifestation and Motion arguing that the petitioners’ motion was moot and academic.
On July 21, 2000, the MTC declared the petitioners’ Motion for Reconsideration abandoned due to their earlier filing of the Notice of Appeal.
The entire record of Civil Case No. 818 was then forwarded to the Regional Trial Court (RTC), Branch 20, Malolos, Bulacan, where the petitioners’ appeal memorandum was submitted on August 24, 2000 and a decision affirming the MTC ruling was rendered on September 20, 2000.

On October 5, 2000, Julita’s sister, Leticia (allegedly asserting her sole ownership of EP No. A-050545, TCT No. T-188-EP), filed a Petition for Quieting of Title with RTC Branch 19.
Prior to the receipt of the RTC Branch 20’s September decision, petitioners filed an Urgent Motion for Suspension of Proceedings on October 9, 2000, which was denied, along with a subsequent Motion for Reconsideration on October 17, 2000.

Petitioners contested the decision of the Court of Appeals (CA) which denied their motion for suspension of the ejectment proceedings based on the pending quieting of title action.
They argued that the nature of the ejectment complaint should be reclassified as an action for unlawful detainer rather than forcible entry, and that the proceedings should be suspended pending a resolution on the conflicting title issue.

The petitioners had been in prior possession of the disputed property with the respondents’ tolerance.
Respondents made a subsequent demand (dated August 26, 1998 and received on August 31, 1998) for the petitioners to vacate the property, which was ignored.

The complaint did not allege any act of force, intimidation, stealth, or strategy by the petitioners in occupying the property.
The respondents’ characterization of the action was ambiguous at times—alternately being described as one for forcible entry and, in parts, for unlawful detainer.

Whether the ejectment case should be considered an action for unlawful detainer (characterized by the absence of force or stealth and based on a tolerance-extended possession) or an action for forcible entry (which requires elements such as force, intimidation, or stealth).

Whether the MTC of Pulilan acquired and validly exercised jurisdiction over the ejectment complaint given that the complaint was filed after a significant lapse of time (considering the one-year prescriptive period for initiating such actions).

Whether the pending civil action for quieting of title (involving a boundary dispute instituted by a third party, Leticia Barnachea) was sufficient to warrant the suspension of the ejectment proceedings.