Consignado v. Court of Appeals
REITERATIONFacts
1. The Antecedents: This case originated from a complaint filed by petitioners Marciana Consignado and Nazario Asendido against respondents Milagros Matining and Heracleo Matining. Petitioners alleged that Marciana Consignado is the absolute owner of a residential property, which she inherited from her father. They claimed that they allowed the respondents to occupy a portion of the property out of charity after the respondents' house burned down. However, the respondents allegedly caused damage to the property by removing the kitchen and dining room without consent and refused to vacate the premises despite repeated demands. Petitioners sought to recover possession, damages for the removal of structures, and compensation for the use and occupation of the property. 2. Procedural History: The Municipal Trial Court (MTC) of Nagcarlan, Laguna, ruled in favor of the petitioners, ordering the respondents to vacate the premises, pay rental value, and attorney's fees. The respondents appealed to the Regional Trial Court (RTC) of San Pablo City, Laguna, which affirmed the MTC's decision. Subsequently, the respondents appealed to the Court of Appeals. The Court of Appeals partially granted the petition, ruling that the respondents were entitled to possession of 11.16 square meters of the property but must vacate the remaining 17.84 square meters, which lawfully pertained to the petitioners and other co-owners. The appellate court also ordered the respondents to pay rental value for the portion they were ordered to vacate. 3. The Petition: The petitioners, Marciana Consignado and Nazario Asendido, filed this petition for review on certiorari with the Supreme Court, challenging the decision of the Court of Appeals. They contend that the Court of Appeals erred in resolving the question of ownership when the case primarily involved possession, and in considering evidence piecemeal. The petitioners also argue that the appellate court based its findings on surmises rather than evidence and improperly changed the theory of the case on appeal. They further question the appellate court's decision to give due course to the private respondents' appeal.
Issue(s)
Whether the Municipal Trial Court (MTC) had jurisdiction over the unlawful detainer case, given the issue of ownership raised by the defendants. Whether the Court of Appeals erred in resolving the question of ownership when the case was primarily about possession. Whether the deed of donation executed by Macario Consignado in favor of the Matining spouses was valid and effective as to Macario's share.
Ruling
The petition is denied, and the judgment of the Court of Appeals is affirmed. The respondents-spouses Milagros and Heracleo Matining are entitled to the possession of 11.16 square meters of the property, and they are ordered to vacate the remaining 17.84 square meters. They are also ordered to pay the fair rental value for the excess portion occupied.
Ratio Decidendi
On the jurisdiction of the MTC and the RTC: The Court reiterated the rule that inferior courts may not be divested of jurisdiction over ejectment cases simply because the defendant sets up a claim of ownership. However, where the question of possession cannot be resolved without passing upon the issue of ownership, because the latter is inseparably linked with the former, the inferior court loses jurisdiction. In this case, the MTC, by deciding the issue of ownership, exceeded its jurisdiction. Nevertheless, the RTC, in the exercise of its original jurisdiction, could try the case on the merits because the parties proceeded to trial without objection to the RTC's jurisdiction. The Court cited Section 11, Rule 40 of the Rules of Court, which allows the Court of First Instance (now RTC) to try a case on the merits in its original jurisdiction if parties file pleadings and go to trial without objection, even if the inferior court lacked jurisdiction. On the Court of Appeals resolving the issue of ownership: The petitioners' contention that the CA erred in resolving ownership is untenable. Since the MTC and RTC had already decided the question of ownership, the CA, on appeal, had to review and resolve the same issue. Furthermore, the petitioners did not object when the lower courts decided the ownership issue in their favor; therefore, they are precluded from assailing the CA's decision on the same issue when it was partially decided against them. On the validity and effect of the deed of donation: The Court of Appeals correctly found the deed of donation to be formally and intrinsically valid. The CA held that the registration of the deed of donation is not a requisite for its validity between the parties. As the deed was valid and no third persons with a better right would be prejudiced, it attained legal efficacy to the extent of Macario's share. The Court further clarified that Macario Consignado, as a co-owner, had the right to alienate his share, which was equivalent to approximately 11.16 square meters. The donation, therefore, conveyed only this aliquot portion, and any occupation beyond this share by the donees (respondents) would be subject to eviction.
Main Doctrine
In ejectment cases, if the question of possession cannot be resolved without passing upon the issue of ownership, the inferior court loses jurisdiction. However, if the parties proceed to trial on the merits without objection to jurisdiction, the appellate court, in the exercise of its original jurisdiction, may try the case.