University Physicians Services, Inc. v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner University Physicians Services, Inc. (UPSI) purchased two parcels of land in Manila, on which the Victoria Apartment building was constructed. Private respondent Jocelyn Pormentira occupied one unit in this building. UPSI sent demand letters to tenants, including Pormentira, to vacate within 60 days. All tenants vacated except Pormentira. On May 7, 1990, UPSI commenced demolition of the apartment building. Procedural History: On May 22, 1990, Pormentira filed a complaint for damages with a prayer for injunctive relief before the Regional Trial Court (RTC) of Manila, Branch IX (Civil Case No. 90-53147), claiming unlawful demolition. On May 24, 1990, UPSI filed an ejectment case against Pormentira before the Metropolitan Trial Court (MTC) of Manila, Branch XX (Civil Case No. 132418). UPSI moved to dismiss Pormentira's damages case on grounds of lack of jurisdiction and litis pendentia. On June 1, 1990, the RTC granted Pormentira's application for a preliminary injunction, ordering UPSI to desist from demolition. On July 30, 1990, the RTC denied UPSI's motion to dismiss and ordered the re-installation of water and electrical connections. The Court of Appeals affirmed the RTC's order, stating that the RTC did not err in acquiring jurisdiction as Pormentira's action was for indemnity due to damages sustained from the demolition. The Petition: Petitioners contend that the damages action should be dismissed because the issue of possession, which is central to the damages claim, must be resolved in the ejectment suit filed before the MTC. The Supreme Court noted that the ejectment case had already been decided by the MTC in favor of UPSI, with subsequent appeals by Pormentira to the RTC and CA being denied. Pormentira's petition for review before the Supreme Court (G.R. No. 113101) was also denied, rendering the issue of precedence moot. The Court then considered whether the damages case should be dismissed.
Issue(s)
Whether the action for damages filed by private respondent should be dismissed on the ground of litis pendentia, given the pendency of an ejectment case between the same parties involving the same subject matter, considering the core issue of possession. Whether the issue of possession, which is the primary issue in an ejectment case, can be the subject of a separate action for damages, and whether the damages claimed are merely incidental to the primary dispute over possession.
Ruling
The petition is GRANTED. The Regional Trial Court of Manila, Br. IX, where Civil Case No. 90-53147 is pending, is hereby ordered to DISMISS said case. Costs against private respondent.
Ratio Decidendi
On the issue of litis pendentia and the precedence of ejectment over damages cases: The Court held that the action for damages filed by private respondent, when examined in its full context, was fundamentally aimed at preventing her ejectment from the premises. The complaint's averments, particularly those seeking to enjoin petitioners from forcing her out and alleging unlawful acts to prejudice her for not vacating, clearly indicate that the core issue was her right to continued possession. The Court reiterated that in ejectment cases, the sole issue is the entitlement to physical possession (possession de facto). Therefore, the determination of whether private respondent had the right to occupy the apartment unit should be resolved in the ejectment suit, not in a separate action for damages. This aligns with the principle of avoiding multiplicity of suits. The Court emphasized that the Rules of Court provide for the dismissal of a complaint if there is a pending action, and the fact that the ejectment case was filed later than the damages case does not preclude the application of this rule. The Court cited Pardo vs. Encarnacion and Teodoro vs. Mirasol to support the principle that issues related to the right of occupancy or renewal of lease can be threshed out in an ejectment suit. The Court found that private respondent's filing of the damages complaint was a preemptive maneuver to block the impending ejectment action. Given that the ejectment case had already proceeded to final judgment in favor of UPSI, the issue of precedence was rendered moot, but the RTC was still ordered to dismiss the damages case to avoid further litigation on the same core issue. On the issue of possession and the nature of damages claimed: While private respondent claimed indemnity for damages, these damages were merely incidental to the primary dispute over possession. The Court found that private respondent's filing of the damages complaint was a preemptive maneuver to block the impending ejectment action. Given that the ejectment case had already proceeded to final judgment in favor of UPSI, the issue of precedence was rendered moot, but the RTC was still ordered to dismiss the damages case to avoid further litigation on the same core issue.
Main Doctrine
An action for damages, the primary issue of which involves the determination of the right to possess a property, should be dismissed on the ground of litis pendentia if a prior or subsequent ejectment case involving the same parties and subject matter is pending, as the issue of possession should be threshed out in the ejectment suit to avoid multiplicity of suits.