Loo Soo v. Osorio
REITERATIONFacts
The Antecedents: Plaintiffs filed a complaint for ejectment against defendants concerning two parcels of land. Defendants claimed that plaintiffs were not the owners, asserting ownership by Geronimo Santiago, and that the sale to plaintiffs was void because plaintiffs, as aliens, are prohibited from acquiring land. Defendants also stated they never dealt with plaintiffs but with Geronimo Santiago. Procedural History: The Justice of the Peace Court dismissed the case. Upon appeal to the Court of First Instance, defendants reiterated their answer. After plaintiffs presented their evidence, defendants moved to dismiss based on lack of jurisdiction due to the issue of ownership. The Court of First Instance sustained the motion and dismissed the case. The Petition: Plaintiffs appealed the dismissal by the Court of First Instance, arguing that the issue of ownership should not divest the lower court of its jurisdiction in an ejectment case.
Issue(s)
Whether the allegation by the defendants that the plaintiffs are constitutionally disqualified from owning land as aliens divests the trial court of its jurisdiction to try an ejectment case.
Ruling
The order appealed from is set aside, and the case is remanded to the lower court for further proceedings.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the lower court erred in dismissing the case because the sole issue in an ejectment proceeding is physical possession (possession de facto) rather than legal ownership (possession de jure). The Court emphasized that a plaintiff's title cannot be collaterally attacked in a summary action for ejectment; the validity of the sale to the plaintiffs can only be challenged in a direct action for annulment. In this instance, the Court noted that the vendor, Geronimo Santiago, had already filed a separate suit to annul the sale, which is the proper legal vehicle for such a challenge. Citing 'Supia v. Quintero', the Court reiterated that the mere filing of an answer claiming title or raising the question of ownership does not divest the Justice of the Peace of jurisdiction. The Court held that as long as the plaintiffs' title has not been finally determined or annulled in a proper action, the defendants cannot confuse the issue of possession by raising questions of title. Thus, the constitutional prohibition against aliens owning land, while relevant to ownership, does not prevent the plaintiffs from seeking the recovery of physical possession from those who refuse to pay rent or who occupy the land without consent.
Main Doctrine
In an action for ejectment, the question of ownership cannot be raised collaterally by the defendants to divest the court of its jurisdiction. The issue in ejectment cases is physical possession, not title de jure, and only the vendor can challenge the title of the vendee in a proper action.