Buazon v. Court of Appeals
REITERATIONFacts
The Antecedents: Nicanor R. Santos, as authorized representative of Bagong Barrio Housing Coop., Inc. (cooperative), claimed ownership over a one-storey, three-door residential structure constructed in 1973. The construction was initiated by Salvador Buazon, then President of the cooperative, with expenses defrayed by Maximo Cabal, a director, who was later reimbursed by the cooperative from rentals. In 1981, Salvador Buazon filed two ejectment cases against lessees Mercedita Mabalay and Cresencia Villanueva, docketed as Civil Cases Nos. 14435 and 14436 before the Metropolitan Trial Court (MTC). The defendants alleged ownership by the cooperative and sale to them by the cooperative's President, Nicanor Santos. The MTC ruled in favor of Buazon, declaring him owner and lessor. This was affirmed by the Regional Trial Court (RTC). Subsequently, Mabalay and Villanueva filed ownership and damages cases against Buazon, leading to a restraining order against the execution of the MTC judgment. The RTC denied their injunction application, which was upheld by the Intermediate Appellate Court and the Supreme Court. After Mabalay and Villanueva vacated, Buazon leased the premises to new lessees, Nick and Nolasco Baldazo. On April 14, 1987, the cooperative, through Nicanor Santos, filed an unlawful detainer case (Civil Case No. 18068) against Buazon and the Baldazos, alleging cooperative ownership and demanding they vacate. Buazon filed an answer, asserting res judicata and challenging the cooperative's legal existence. Procedural History: The MTC, Branch 50, rendered judgment on April 11, 1988, in favor of the cooperative, ordering the defendants to vacate. Buazon appealed to the RTC, invoking res judicata based on the prior judgment in Civil Case Nos. 14435 and 14436. On November 11, 1988, the RTC sustained Buazon's defense, set aside the MTC decision, and dismissed the case. The cooperative's motion for reconsideration was denied. The cooperative appealed to the Court of Appeals (CA), which reversed the RTC decision and reinstated the MTC ruling. The Petition: Petitioners (Salvador Buazon, Nick Baldazo, and Nolasco Baldazo) assailed the CA decision, raising issues of MTC jurisdiction due to non-compliance with B.P. Blg. 25, the propriety of applying the Rule on Summary Procedure despite the ownership question, and the erroneous disregard of res judicata by the CA.
Issue(s)
Whether the Metropolitan Trial Court lacked jurisdiction over the unlawful detainer case due to the respondent cooperative's alleged non-compliance with Section 5(c) of Batas Pambansa Blg. 25. Whether the Metropolitan Trial Court erred in applying the Rule on Summary Procedure in an unlawful detainer case where the question of ownership was raised. Whether the Court of Appeals erred in disregarding the principle of res judicata against the respondent cooperative.
Ruling
The petition is devoid of merit. The Court affirmed the decision of the Court of Appeals, reinstating the Metropolitan Trial Court's decision in favor of the respondent cooperative. The dispositive portion of the Court of Appeals' decision was upheld.
Ratio Decidendi
On the issue of MTC jurisdiction and non-compliance with B.P. Blg. 25: The Court held that the jurisdiction of a court is determined by law, and inferior courts are vested with exclusive jurisdiction over unlawful detainer cases. Non-compliance with Section 5(c) of B.P. Blg. 25, which requires alleging the need for the premises, is at best a ground for dismissal for lack of cause of action or an affirmative defense that must be raised in the answer. Since the petitioners failed to raise this ground in a motion to dismiss or as an affirmative defense in their answer, they are deemed to have waived it. Therefore, the Metropolitan Trial Court properly exercised its jurisdiction. On the application of the Rule on Summary Procedure despite the ownership question: The Court reiterated that Section 1(A)(1) of the Rule on Summary Procedure mandates its application to unlawful detainer cases. Furthermore, Section 33(2) of B.P. 129 grants Metropolitan Trial Courts exclusive original jurisdiction over such cases, with the proviso that if the defendant raises ownership, the court can resolve it only to determine possession. Inferior courts are not divested of jurisdiction in ejectment cases merely because a claim of ownership is set up. If the complaint establishes jurisdictional facts and the remedy sought is possession, the court has jurisdiction regardless of ownership claims. The Court also noted that the petitioners' failure to object to the application of the Rule on Summary Procedure, which involved submitting position papers and affidavits, constituted a waiver of any procedural objection. On the application of res judicata: The Court ruled that the principle of res judicata cannot apply against the respondent cooperative because it was never impleaded as a party in the prior Civil Case Nos. 14435 and 14436, nor was it a successor-in-interest or real party in interest in those actions. Since the cooperative was not a party to the previous decisions, it cannot be bound by them, even if it was aware of the pendency of the cases. The Court emphasized that judgments in forcible entry or detainer cases are effective only with respect to possession and do not bind title or ownership, citing Section 7, Rule 70 of the Rules of Court. Therefore, the prior judgment declaring Salvador Buazon as owner and lessor was conclusive only as to the issue of material possession between him and the defendants in those cases, not as to the ownership claim of the cooperative.
Main Doctrine
The Metropolitan Trial Courts have exclusive original jurisdiction over unlawful detainer cases, and they may apply the Rule on Summary Procedure even when the question of ownership is raised, provided that the issue of possession cannot be resolved without determining the issue of ownership. The principle of res judicata does not apply to parties who were not impleaded in the prior action.