Torres vda. de Cruz v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Silvina Torres Vda. de Cruz and private respondent Priscilla Cruz-Gatchalian are sisters-in-law. Private respondent and her siblings inherited a parcel of land from their mother. A portion of this land, 693 sq. m., is covered by OCT No. P-397-C issued in the name of private respondent. Petitioner and her children built a house on this 693 sq. m. lot. Procedural History: On May 29, 1989, private respondent sent a letter demanding petitioner vacate the premises. After conciliation failed, private respondent filed an unlawful detainer case before the Municipal Trial Court (MTC) of Bulacan, Bulacan. Petitioner denied private respondent's ownership, claimed ownership based on a tax declaration, and alleged she had filed a prior complaint for reconveyance before the Regional Trial Court (RTC), arguing the MTC lacked jurisdiction. The MTC ruled in favor of private respondent. The RTC affirmed the MTC decision. The Court of Appeals (CA) affirmed the RTC decision, upholding the MTC's jurisdiction and private respondent's right to material possession. The Petition: Petitioner argues that the issue of ownership is primary and must be resolved first, thus ousting the MTC of jurisdiction. She contends that possession cannot be determined without resolving ownership, citing Dante v. Sison and Ching v. Malaya.
Issue(s)
Whether the Municipal/Metropolitan Trial Court is ousted of jurisdiction in an unlawful detainer case when the issue of ownership is raised. Whether the filing of a separate action for reconveyance or annulment of title by the defendant in an ejectment case affects the jurisdiction of the ejectment court.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the jurisdiction of the Municipal Trial Court and the right of the private respondent to material possession. The Court ruled that the MTC retains jurisdiction over ejectment cases even when ownership is intertwined with possession, provided the determination of ownership is solely for the purpose of resolving possession.
Ratio Decidendi
On the issue of jurisdiction in ejectment cases when ownership is raised: The Court reiterated that under Batas Pambansa Blg. 129 (The Judiciary Reorganization Act of 1980), inferior courts now retain jurisdiction over an ejectment case even if the question of possession cannot be resolved without passing upon the issue of ownership. This is with the express qualification that such issue of ownership shall be resolved only for the purpose of determining the issue of possession. The fact that the issues of ownership and possession de facto are intricately interwoven will not cause the dismissal of the case for forcible entry and unlawful detainer on jurisdictional grounds. The pronouncement made by the inferior court affecting ownership is to be regarded merely as provisional and does not bar or prejudice an action between the same parties involving title to the land. The jurisdiction of a court over the subject matter is determined by the allegations of the complaint, and since the complaint sufficiently qualified the case as one for ejectment, the inferior court acquired jurisdiction. On the effect of filing a separate action for reconveyance or annulment of title: The Court held that the filing of an action for reconveyance or annulment of title over the same property does not divest the Municipal Trial Court of its jurisdiction to try the forcible entry or unlawful detainer case before it. This is because, while there may be identity of parties and subject matter, the rights asserted and the relief prayed for are not the same. The respondents in ejectment proceedings cannot defeat the summary nature of the action against them by simply filing an action questioning the ownership of the person who is trying to eject them from the premises. The excerpt quoted from Dante v. Sison and Ching v. Malaya was clarified to mean that the exception applies when the issue of possession cannot be decided without deciding ownership, but the subsequent ruling in Dante v. Sison itself, which was cited by petitioner, is precisely against petitioner's position.
Main Doctrine
The Municipal/Metropolitan Trial Court retains jurisdiction over ejectment cases even if the issue of possession cannot be resolved without passing upon the issue of ownership, provided that the determination of ownership is made only for the purpose of resolving the issue of possession. The filing of an action for reconveyance or annulment of title does not divest the MTC of its jurisdiction to try the ejectment case.