Corpuz v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Carlito Corpuz filed an unlawful detainer case against respondent Juanito Alvarado for recovery of possession of a room. Corpuz had purchased a house from Lorenzo Barredo, who was the original landlord of both Corpuz and Alvarado. Alvarado and other tenants had executed an "Affidavit of Waiver" granting Barredo the right to sell the property. After the sale to Corpuz, a tenancy relationship was established between Corpuz and Alvarado. Corpuz demanded Alvarado vacate the room, citing his children's need for it, but Alvarado refused. Procedural History: The Metropolitan Trial Court (MTC) ordered Alvarado to vacate. On appeal, the Regional Trial Court (RTC) reversed the MTC decision, finding that the sale between Corpuz and Barredo was subject to a controversy pending before the National Housing Authority (NHA) and that the "Affidavit of Waiver" was a forgery. The RTC dismissed the unlawful detainer case. The Court of Appeals affirmed the RTC's decision. Corpuz then elevated the case to the Supreme Court. The Petition: The Supreme Court was asked to determine if the unlawful detainer suit should be suspended pending resolution of the NHA case and whether the "Affidavit of Waiver" was authentic. Corpuz argued that the assertion of ownership challenges did not divest the MTC of its jurisdiction.
Issue(s)
Whether the unlawful detainer suit should be suspended pending resolution of the case lodged in the National Housing Authority (NHA) impugning the sale of the property. Whether the "Affidavit of Waiver" between Corpuz and Barredo was authentic. Whether the ejectment suit was properly referred to the Lupon Tagapayapa.
Ruling
The petition is impressed with merit. The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the assailed decision of the Court of Appeals, and REINSTATED the judgment of the Metropolitan Trial Court, Manila, Branch 6, ordering Alvarado to vacate the room.
Ratio Decidendi
On the suspension of the unlawful detainer suit pending resolution of the NHA case: The Court reiterated the elementary principle that the MTC has exclusive jurisdiction over ejectment cases, where the sole issue is physical possession (possession de facto). While inferior courts may look into evidence of title or ownership to determine the nature of possession, they cannot resolve the issue of ownership itself. The Court cited Refugia v. Court of Appeals and De la Santa vs. Court of Appeals, emphasizing that suits for annulment of sale, title, or document do not abate ejectment actions. The rationale is to prevent defendants from trifling with summary ejectment suits by simply asserting ownership. Therefore, the controversy pending before the NHA regarding the annulment of the Deed of Sale and the authenticity of the "Affidavit of Joint Waiver" could not deter the MTC from taking cognizance of the ejectment suit for the purpose of determining better possessory right. The defendant is not without remedy, as a judgment in an ejectment case does not bar a subsequent action respecting title to the property. On the authenticity of the "Affidavit of Waiver": The Court noted that the RTC concluded the "Affidavit of Waiver" was a forgery, and the Court of Appeals affirmed this. However, the Supreme Court's primary focus was on the jurisdiction of the MTC in an unlawful detainer case, and the issue of ownership, including the authenticity of the waiver, was deemed secondary to the determination of immediate possession. The Court's reversal was based on the principle that such issues should not suspend the ejectment proceedings. On the referral to the Lupon Tagapayapa: The Court found Alvarado's defense regarding non-referral to the Lupon Tagapayapa to be without merit. This defense was merely stated in a single general sentence in Alvarado's answer, without any supporting reason or explanation, which constitutes a waiver of the defense. Furthermore, the Court stressed that the proceeding outlined in Presidential Decree No. 1508 is not a jurisdictional requirement, and non-compliance therewith cannot affect the jurisdiction already acquired by the lower court over the subject matter and parties. Therefore, this procedural defect, even if properly raised, would not have abated the ejectment suit.
Main Doctrine
An unlawful detainer suit, being summary in nature, should not be abated by the mere assertion of ownership or the pendency of a case questioning the validity of the sale of the property before another agency, as the primary issue in ejectment cases is physical possession.