Feliciano v. Court of Appeals
REITERATIONFacts
The Antecedents: Eleuterio Cosme obtained a P50,000.00 loan from Insular Bank of Asia and America, secured by a mortgage on his land. Upon default, the mortgage was foreclosed, and the bank became the owner after the redemption period expired. Eleuterio Cosme and his wife Asuncion Obando died, and their daughters, Elisa C. Feliciano and Arsenia C. Buendia, took possession as heirs. Elisa filed an action for Annulment of Mortgage, Certificate of Sale, Deed of Absolute Sale, Reconveyance, Preliminary Injunction, and Damages against the bank. During this pendency, Ernesto Baron purchased the property from the bank. Baron demanded rent and vacation of the premises from Elisa and Arsenia. Elisa refused, asserting ownership and the pending litigation. Baron then filed an ejectment case before the Metropolitan Trial Court (MeTC). Procedural History: The MeTC dismissed Baron's ejectment case on the ground of litis pendentia. The Regional Trial Court (RTC) affirmed the MeTC's decision, adding that the MeTC lacked jurisdiction due to insufficient averments for forcible entry or unlawful detainer. Baron appealed to the Court of Appeals (CA), which reversed the RTC, holding that litis pendentia was absent due to different rights asserted and reliefs prayed for, and that the ejectment complaint sufficiently established a cause for unlawful detainer. Petitioner Elisa C. Feliciano now seeks review of the CA's decision. The Petition: Petitioner Elisa C. Feliciano argues that the CA erred in misapplying the laws and jurisprudence on litis pendentia and jurisdiction. She contends there is identity of rights and reliefs in both the RTC and MeTC cases, and that a judgment in the RTC case would constitute res judicata in the ejectment case, thus warranting dismissal based on litis pendentia. She also asserts that the ejectment complaint lacks sufficient allegations to establish unlawful withholding of possession, thus failing to vest jurisdiction in the MeTC.
Issue(s)
Whether litis pendentia exists between the action for annulment of mortgage and reconveyance filed by petitioner and the ejectment case filed by respondent. Whether the allegations in the ejectment complaint sufficiently establish a cause of action for unlawful detainer to vest jurisdiction in the Metropolitan Trial Court.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed, and the case is remanded to the court of origin for further proceedings.
Ratio Decidendi
On the issue of litis pendentia: The Court held that litis pendentia does not obtain in this case due to the absence of the second and third requisites. While there may be an identity of parties and subject matter, the issues and reliefs prayed for are not the same. The annulment and reconveyance suit concerns the validity of the mortgage and foreclosure sale, seeking recovery of ownership. In contrast, the ejectment case, assuming the validity of the sale, focuses on the right to possess the property, seeking restoration of possession. Therefore, the Metropolitan Trial Court can validly try the ejectment case concurrently with the Regional Trial Court's annulment suit. A judgment in one case will not constitute res judicata in the other because the causes of action are different. The test for identity of causes of action, which is whether the same evidence is sufficient for both, is not met here, as different sets of evidence are required for annulment and ejectment. Moreover, well-settled jurisprudence dictates that the pendency of an action for annulment of sale and reconveyance cannot be pleaded in abatement of an action for unlawful detainer or forcible entry, as the latter's judgment is effective only with respect to possession and does not bind title or ownership. This rule prevents defendants from frustrating ejectment cases by simply filing actions contesting ownership in a higher court. On the sufficiency of the ejectment complaint and jurisdiction: The Court reiterated that in determining the sufficiency of a complaint, the test is whether the court can render a valid judgment based on the alleged facts. The ejectment complaint alleged that the plaintiff bought the premises, that the defendant was requested to vacate for lack of lawful possession and non-payment of rentals, and that the defendant claimed ownership. These allegations adequately established a cause of action for unlawful detainer, vesting jurisdiction in the MeTC. The Court noted that an allegation of unlawful withholding of possession is sufficient, and the complaint need not use the exact legal terminology if the factual averments clearly indicate unlawful detainer. The Court of Appeals correctly observed that the complaint sufficiently established a cause for unlawful detainer, laying proper jurisdiction.
Main Doctrine
The pendency of an action for annulment of sale and reconveyance may not be successfully pleaded in abatement of an action for unlawful detainer or forcible entry, as the judgment in the latter case pertains only to possession and does not bind the title or affect ownership.