Title
Dante vs. Sison
Case
G.R. No. 82761
Decision Date
Jun 29, 1989
Petitioners claim ownership of property purchased from Josephine Pacadaljin; respondents allege fraud, file annulment case. SC rules forcible entry case proceeds independently of annulment case, as possession and ownership issues are distinct.

Case Summary (G.R. No. 215568)

Nature of the Case

This litigation represents a petition for certiorari and injunction, seeking to reverse the decisions of the Court of Appeals which dismissed the petitioners' action regarding forcible entry against the respondents. The underlying dispute is focused on possession of a residential property in Quezon City, which the petitioners claim to have purchased.

Factual Background

On January 23, 1987, the petitioners filed a forcible entry complaint, asserting that they are the rightful occupants of a property they purchased from Josephine Pacadaljin, the allegedly registered owner. However, the respondents countered these claims with allegations that they are actually the rightful heirs of the deceased Loreta Pacadaljin, the property's original owner, and contended that the sale to the petitioners was null due to alleged falsification of documents by Josephine.

Legal Proceedings Timeline

In June 1987, amid the ejectment proceedings, the respondents initiated a complaint for annulment of sale against Josephine Pacadaljin, the petitioners, and John Doe "who might be the new buyer." An order for a preliminary injunction was issued by the Regional Trial Court to pause the ejectment proceedings until the annulment case was resolved.

Jurisdictional Considerations

The crucial legal question presented is whether an ejectment case may be stayed due to an annulment of sale case pending in another court. The Supreme Court of the Philippines ruled against staying the ejectment proceedings, affirming that the jurisdiction of the Metropolitan Trial Court is not divested by the subsequent filing of an annulment case involving the same property.

Legal Reasoning

The Court's decision rests on prior jurisprudence, asserting that the summary nature of unlawful detainer actions emphasizes the need for prompt resolutions regarding possession. Specifically, the Supreme Court clarified that even if ownership is contested in a separate case, it does not justify halting the ejectment process since the actionable issue in forcible entry cases is possession, not ownership.

Summary of Court Precedents

The Court referenced multiple precedents reaffirming its stance that claims of ownership made in defense of an ejectment action do not oust the municipal court’s jurisdiction to resolve po

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