Del Rosario v. Court of Appeals
REITERATIONFacts
The Antecedents: This case originated from an ejectment suit concerning a house and lot in Quezon City. The property was mortgaged by spouses Oseas and Loreta del Rosario, through their attorney-in-fact, petitioner Dennis del Rosario, to private respondent Jose Luna for P450,000.00. When the spouses defaulted on the loan, petitioner, acting as attorney-in-fact, sold the property to private respondent for the same amount. The spouses were given an opportunity to buy back the property but failed to do so, leading to the cancellation of the original title and the issuance of a new one in private respondent's name. Petitioner was allowed to remain in the property temporarily. Procedural History: After petitioner failed to vacate the premises despite repeated demands and extensions, private respondent filed an ejectment complaint before the Metropolitan Trial Court (MTC) of Quezon City. Petitioner contested the MTC's jurisdiction, arguing that a pending action for quieting of title involving the same parties and property, filed by his father, divested the MTC of its authority. The MTC ruled in favor of private respondent, ordering petitioner to vacate and pay monthly compensation. Petitioner's appeals to the Regional Trial Court (RTC) and the Court of Appeals (CA) were unsuccessful, with both courts affirming the MTC's decision. The CA denied petitioner's motion for reconsideration. The Petition: Petitioner seeks review of the Court of Appeals' decision, faulting the appellate court for not conducting a hearing to resolve factual issues and for not holding that the lower court lacked jurisdiction. Petitioner argues that the issue of ownership, raised in the pending quieting of title case, should have precluded the MTC from exercising jurisdiction over the ejectment suit. He also contends that the CA should have conducted a trial to determine the genuineness of the sale and the nature of the transaction. The Supreme Court, however, found the petition devoid of merit, affirming the MTC's jurisdiction based on the nature of ejectment cases and the applicability of the Revised Rules on Summary Procedure, which allow adjudication based on affidavits and position papers.
Issue(s)
Whether the Metropolitan Trial Court had jurisdiction over the ejectment suit despite the pendency of an action for quieting of title. Whether the Court of Appeals erred in not conducting a hearing to resolve the factual issue of ownership. Whether the Revised Rules on Summary Procedure apply to the ejectment case.
Ruling
The petition is devoid of merit. The Supreme Court affirmed the decision of the Court of Appeals. The Metropolitan Trial Court correctly exercised its exclusive original jurisdiction over the ejectment suit. The Court of Appeals did not err in not conducting a hearing, as summary procedure allows adjudication based on affidavits and position papers. The Revised Rules on Summary Procedure apply to ejectment cases regardless of the issue of ownership.
Ratio Decidendi
On the jurisdiction of the Metropolitan Trial Court: The Court reiterated that the Metropolitan Trial Court has exclusive original jurisdiction over ejectment cases, as provided by Batas Pambansa Blg. 129. The jurisdiction is determined by the allegations in the complaint, which in this case, was an action for ejectment. The pendency of a separate action for quieting of title between the same parties does not divest the MTC of its jurisdiction over the ejectment case, as the issue in ejectment is the right to physical possession (possession de facto), independent of claims of ownership (possession de jure). The Court emphasized that judgments in ejectment suits do not bar actions respecting title to the land. On the Court of Appeals' failure to conduct a hearing: The Court held that under the Revised Rules on Summary Procedure, which applies to ejectment cases, adjudication can be made based on affidavits and position papers. The court is no longer allowed to hold a hearing to receive testimonial evidence, unless it finds it necessary to clarify issues and requires parties to submit additional affidavits or evidence. This summary nature is crucial for the swift disposition of possession cases, which often threaten societal peace. Therefore, the CA did not err in relying on the submitted documents. On the applicability of the Revised Rules on Summary Procedure: The Court clarified that under the Revised Rules on Summary Procedure, all ejectment cases are covered by summary procedure, irrespective of whether the issue of ownership is pleaded. The fact that the ejectment case was filed before the effectivity of the Revised Rules on Summary Procedure does not matter, as procedural rules may be given retroactive application. Remedial statutes can be applied to pending cases, and there are no vested rights in rules of procedure. Thus, the summary procedure was correctly applied.
Main Doctrine
The jurisdiction of a Metropolitan Trial Court in an ejectment case is determined by the allegations in the complaint, not by the defense raised by the defendant. Furthermore, under the Revised Rules on Summary Procedure, ejectment cases are covered by summary procedure regardless of whether the issue of ownership is pleaded, and adjudication can be based on affidavits and position papers without the need for a hearing.