Title
Gayoso vs. Twenty-Two Realty Development Corp.
Case
G.R. No. 147874
Decision Date
Jul 17, 2006
Dispute over possession of a Mandaluyong lot; petitioners claimed void sale, but SC upheld MeTC jurisdiction, ruling possession, not ownership, was primary issue.
jurisdiction
unlawful detainer complaint
ownership

Case Summary (G.R. No. 147874)

Factual Background

Respondent alleged that on October 11, 1954, Victoriano Gayoso (later deceased) sold a lot located on Mariveles corner Calbayog Streets, Mandaluyong City to Prospero Almeda. After the sale, Almeda allowed Gayoso and his children, who are the present petitioners, to remain on the property as lessees. They allegedly paid P20.00 a month in rentals. Respondent further alleged that Almeda’s heirs later sold the same lot to respondent corporation. Accordingly, on February 19, 1996, the title to the property was transferred in respondent’s name. Respondent then claimed that petitioners stopped paying rentals, prompting it to send letters dated September 12 and October 17, 1996 demanding that petitioners vacate. Upon petitioners’ refusal, respondent filed an ejectment case with the MeTC.

Initiation of the Ejectment Case and MeTC Ruling

Respondent’s ejectment complaint was filed on December 12, 1996 with the MeTC and docketed as Civil Case No. 15340. The complaint was framed as unlawful detainer, based on petitioners’ alleged failure to pay rentals for more than three months and their continued refusal to vacate notwithstanding demand. In their answer, petitioners denied respondent’s allegations with specificity and raised a jurisdictional defense. They maintained that the MeTC had no jurisdiction because they were raising an issue of ownership in their pleadings. They asserted that their father sold the lot, which they characterized as conjugal property, to Almeda without the consent of their mother, rendering the sale void. Petitioners thus argued that Almeda could not have transferred ownership to respondent.

On July 21, 1997, the MeTC rendered judgment ordering petitioners to vacate and to surrender possession to respondent. The MeTC also ordered petitioners to pay respondent P4,000.00 representing unpaid rentals beginning February 1981 to December 1996, to pay P20.00 per month thereafter until the premises were vacated, and to pay P10,000.00 as attorney’s fees, plus costs of suit. The MeTC dismissed petitioners’ counterclaim. The MeTC’s approach was anchored on the alleged nonpayment of rentals for more than three months, from which it concluded that respondent had the right to evict under the applicable ejectment principles.

RTC and Court of Appeals Proceedings

Petitioners appealed to the RTC, Branch 213, Mandaluyong City. The RTC affirmed the MeTC decision. It found that petitioners’ refusal to vacate and to pay rentals established a clear case of unlawful detainer, and that the MeTC possessed jurisdiction to resolve the dispute.

Petitioners then sought relief from the Court of Appeals via a Petition for Review under Rule 42 of the 1997 Rules of Civil Procedure, as amended. In its Decision dated April 20, 2001 in CA-G.R. SP No. 48001, the Court of Appeals dismissed the petition and affirmed in toto the RTC decision. The appellate court thereby upheld the MeTC’s authority to try and decide the unlawful detainer case, notwithstanding petitioners’ insistence that ownership was in issue.

The Parties’ Contentions in the Petition

Before the Court, petitioners argued that the issue of ownership was inextricably linked with the issue of possession. They maintained that because the determination of ownership was necessary, the MeTC lacked jurisdiction over the case.

Respondent countered that the real question concerned entitlement to possession. It argued that even if petitioners raised an ownership issue in their pleadings, such issue did not divest the MeTC of jurisdiction because the ejectment case primarily required resolution of possession.

Legal Basis and Reasoning on Jurisdiction

The Court held for respondent. It emphasized the rule that jurisdiction is conferred by law. It pointed to Section 33 of Batas Pambansa Blg. 129, as amended, which provides that Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts have exclusive original jurisdiction over cases of forcible entry and unlawful detainer, with a proviso that when the defendant raises ownership in his pleadings and the question of possession cannot be resolved without deciding ownership, the issue of ownership is to be resolved only to determine possession.

The Court further relied on Rule 70, Section 18 of the 1997 Rules of Civil Procedure, as amended, which provides that a judgment in forcible entry or detainer is conclusive only with respect to possession and does not bind title nor affect ownership. It also reiterated that such judgment does not bar an action between the same parties regarding title or ownership, and that the RTC decides the matter on the basis of the entire record in the court of origin.

In support, the Court cited Barba vs. Court of Appeals for the doctrine that inferior courts retain jurisdiction in ejectment cases even when ownership is raised in the pleadings and possession cannot be resolved without passing upon ownership. The Court explained that such inferior courts have the competence to provisionally resolve the issue of ownership solely to determine possession. It stressed that this provisional determination does not bind title, does not affect ownership, and does not preclude later actions involving title under a different cause of action.

The Court also cited Tala Realty Services Corporation vs. Banco Filipino Savings and Mortgage Bank, which held that ejectment cases fall within the jurisdiction o

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