Case Summary (G.R. No. 179011)
Applicable Law and Procedural History
The case involves the application of Article 487 of the 1987 Philippine Civil Code allowing any co-owner to file an action in ejectment without joining all co-owners, and Sections 1, Rule 70 of the Rules of Court on unlawful detainer. The case was initially decided by the Municipal Trial Court (MTC), affirmed in part by the Regional Trial Court (RTC), reversed by the Court of Appeals (CA), and finally brought before the Supreme Court.
Facts and Claims of Parties
Petitioner claimed ownership as a co-heir and co-owner of Lot No. 5, alleging that respondents unlawfully withheld possession of the lot despite repeated demands for eviction. Respondents argued that Mildred Kascher, sister of respondent Margie, is the actual owner of the residential building on the lot, as shown by a tax declaration in her name, supported by a supposed contract to sell between Mildred and Maximo Catedrilla (petitioner’s father) memorialized in an amicable settlement before the Barangay Lupon. Respondents further asserted the case was barred by prior judgment due to this amicable settlement and counterclaimed for damages.
Decisions of Lower Courts
The MTC ruled in favor of petitioner, ordering respondents to vacate the property, awarding attorney's fees and compensation, and dismissing the counterclaim for lack of evidence. It held that petitioner, as a co-owner, was entitled to recover possession, and respondents were mere occupants without title. The RTC affirmed the MTC decision except deleting attorney's fees for lack of basis and ruled the amicable settlement before the Barangay was unenforceable and that tax declarations are not proof of ownership. The RTC held Mildred was not an indispensable party as she was not in actual possession. Respondents’ motion for reconsideration was denied.
Court of Appeals’ Reversal and Grounds
The CA reversed the RTC and MTC decisions, dismissing petitioner’s ejectment complaint. It held that all co-owners must be impleaded as plaintiffs under Sections 1, Rule 7 and 7, Rule 3 of the Rules of Court for the action to proceed, deeming petitioner’s sole filing fatally defective for non-joinder of indispensable parties. The CA also determined that Mildred Kascher was the true owner of the residential building and therefore an indispensable party who should have been impleaded. The CA found that ejectment was an inappropriate remedy under the circumstances because the dispute involved possessory rights complicated by ownership claims and a purported contractual arrangement.
Issues on Review before the Supreme Court
Petitioner challenged the CA’s ruling, contending that (1) the decision of the trial courts was not a nullity despite non-joinder of co-owners; and (2) the CA erred in holding that he knew Mildred was the real owner of the residential building on the lot, thus requiring her impleading as a party.
Supreme Court’s Ruling on Co-ownership and Indispensable Parties
The Supreme Court ruled that under Article 487 of the Civil Code, any co-owner may initiate an ejectment action without the necessity of joining all co-owners, as the suit is considered to be for the benefit of all. The other co-owners are not indispensable parties because complete relief can be afforded in their absence. Jurisprudence confirmed that only the co-owner who filed the suit is indispensable. Petitioner’s complaint was therefore valid despite the absence of other co-heirs as plaintiffs.
Supreme Court’s Findings on Ownership and Possession Issues
The Court found no basis to treat Mildred Kascher as an indispensable party. The affidavits relied upon by the CA only showed negotiation attempts to sell the lot to Mildred but did not establish that she was the actual owner of the house or had perfected ownership. The amicable settlement before the Barangay was executed between Maximo and respondent Margie on behalf of their parties and did not establish ownership in Mildred. Furthermore, the settlement was repudiated due to non-compliance by respondents and therefore rescinded under Article 2041 of the Civil Code, entitling petitioner to pursue ejectment. The receipt for downpayment signed by Teresito Castigador was also insufficient to prove a perfected contract or Mildred’s ownership since no authority was established.
Clarification on the Nature of Ejectment and Unlawful Detainer
The Court emphasized that ejectment is a summary remedy concerning possession, not ownership. The issue is who is entitled to physical possession, independe
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Case Syllabus (G.R. No. 179011)
Background and Nature of the Case
- Petitioner Rey Castigador Catedrilla filed a complaint for ejectment against respondents Mario and Margie Lauron before the Municipal Trial Court (MTC) of Lambunao, Iloilo.
- The complaint alleged ownership of Lot 183 located in Mabini Street, Lambunao, Iloilo, originally owned by Lorenza Lizada, deceased since February 13, 1972.
- Lorenza’s sole heir, Jesusa Lizada LosaAes, married to Hilarion Castigador, succeeded to the property; they had children including Lilia Castigador (petitioner’s mother).
- Upon the death of the Castigador spouses, their heirs subdivided Lot 183; Lot No. 5 was apportioned to Lilia’s heirs, including petitioner by virtue of inheritance.
- Respondents, with the tolerance of Lilia’s heirs, constructed a residential building on Lot No. 5 around 1980.
- Demands for respondents to vacate the premises were made but ignored, prompting the ejectment action.
- Respondents answered that they were not owners but occupants of the house for Mildred Kascher (Margie’s sister), who had allegedly paid a downpayment for the lot, citing an amicable settlement executed in 1998 before the Barangay Lupon.
Trial Court Findings and Ruling
- The MTC ruled in favor of petitioner ordering respondents to vacate the lot and restore possession, awarding attorney’s fees and reasonable compensation.
- The court found petitioner to be a co-owner and authorized person to file the ejectment suit under Article 487 of the Civil Code and Rule 70 of the Rules of Court.
- Respondents were found to be unlawful possessors occupying without ownership or lease contract.
- The MTC did not find Mildred Kascher to be an indispensable party, noting that even a payment receipt signed by Teresito Castigador failed to establish authority to sell the property.
- The nature of ejectment was emphasized as focusing on superior right to possession rather than ownership.
Regional Trial Court (RTC) Decision
- The RTC affirmed the MTC decision except for the deletion of ordered attorney’s fees due to lack of basis.
- It held that the amicable settlement before the Barangay Lupon was unenforceable as Maximo (petitioner’s father) failed to comply with terms.
- The tax declaration in Mildred’s name was held not to be conclusive evidence of ownership.
- Mildred was not deemed an indispensable party as she was not in actual possession of the lot.
- Respondents’ motion for reconsideration was denied.
Court of Appeals (CA) Ruling and Grounds for Reversal
- The CA reversed and set aside the RTC and MTC decisions, dismissing petitioner’s complaint.
- It ruled that petitioner failed to implead all co-heirs as plaintiffs, a fatal defect since all co-owners are indispensable parties.
- The CA held that Mildred Kascher was an indispensable party due to petitioner’s knowledge of her ownership of the residential building.
- The CA stressed the necessity of indispensable parties for valid exercise of judicial po