Alvarez v. Court of Appeals
REITERATIONFacts
The Antecedents: Spouses Domingo and Celia Garcia purchased a parcel of land in Quezon City in 1978, which was registered under their name. They subsequently fenced the property and left for the United States. Upon their return in 1995, they discovered that their fence had been removed and portions of their land were occupied by individuals who had constructed houses. These occupants claimed to be leasing the property from Octavio Alvarez, who had allegedly purchased it from Amparo Lasam. Unable to reach a settlement, the Garcias filed a complaint for forcible entry against the occupants, later amended to implead Octavio Alvarez, Charlie Robles, and Marilyn Cortez. Procedural History: The Metropolitan Trial Court (MeTC) of Quezon City ruled in favor of the Garcias, ordering Alvarez, Robles, and Cortez to vacate the property, remove their structures, and pay monthly compensation, attorney's fees, and costs. The petitioners appealed this decision to the Regional Trial Court (RTC) without filing a supersedeas bond. While the appeal was pending, the respondents filed a motion for execution, which the trial court granted, issuing a writ of demolition. The RTC affirmed the MeTC's decision. The petitioners then filed a petition for review with the Court of Appeals, arguing that the lower courts had not properly appreciated their evidence. The Court of Appeals denied their petition and a subsequent motion for reconsideration. The Petition: The petitioners seek a reversal of the Court of Appeals' decision, alleging that it sanctioned a departure from the accepted and usual course of proceeding. Their arguments include that the appellate court erred in ruling on the issue of ownership in an ejectment case, in not holding that their right to the property prevailed due to prior physical possession, and in refusing to give weight to their documentary evidence, specifically a deed of sale and a special power of attorney. They also contend that the writ of demolition was irregularly issued. The core issues presented to the Supreme Court are whether the lower courts erred in resolving ownership in a forcible entry case, in disregarding alleged prior possession by the petitioners, and in not giving credence to the petitioners' evidence.
Issue(s)
Whether the Court of Appeals and lower courts erred in ruling on the issue of ownership in a forcible entry case. Whether the Court of Appeals erred in disregarding any finding that petitioners had prior physical possession. Whether the Court of Appeals erred in not according credence and probative value to the documents submitted by petitioners, specifically a Deed of Sale and a Special Power of Attorney, which purportedly evidenced petitioners' ownership. Whether the Court of Appeals erred in not holding that the issuance of the writ of demolition by the trial court was irregular.
Ruling
The petition is denied. The assailed decision of the Court of Appeals, which upheld the rulings and findings of the courts below, is affirmed. Costs against petitioners.
Ratio Decidendi
On the issue of ruling on ownership in an ejectment case: The Supreme Court reiterated that in ejectment cases, the lower court may decide the issue of ownership if it is intertwined with the question of possession. This is explicitly provided for in Batas Pambansa Blg. 129 and Section 16, Rule 70 of the Rules of Court, which grant inferior courts jurisdiction to determine ownership questions provisionally to resolve the issue of possession. In this case, the petitioners themselves raised ownership as an affirmative defense by presenting a Deed of Sale and a Special Power of Attorney, thereby placing the question of ownership directly in issue to establish their right to possession. Therefore, the inferior courts and the Court of Appeals were necessitated to resolve the issue of ownership to properly decide who is entitled to possession. On the alleged finding of prior physical possession: The Court clarified that the portion of the Court of Appeals' decision petitioners referred to as a finding of prior possession was merely a narration restating the petitioners' own allegations, not an actual finding of fact by the appellate court. Therefore, it was misleading for the petitioners to claim that the Court of Appeals made such a finding, as nothing in the narration supported their contention. The appellate court's decision did not contain any finding that the petitioners had prior physical possession of the lot in dispute. On the probative value of petitioners' documentary evidence: The Supreme Court upheld the Court of Appeals' decision to disregard the xerox copies of the Deed of Sale and the Special Power of Attorney presented by the petitioners. The CA found these documents inadmissible and lacking probative weight because the petitioners failed to append the original Special Power of Attorney, the copies were mere xeroxes, and Amparo Lasam, the alleged buyer, did not register the deed nor secure title in her name. Furthermore, petitioners failed to adduce evidence of a deed evidencing the sale from Amparo Lasam to petitioner Octavio Alvarez. The Court emphasized that questions of possession and ownership are intertwined and factual matters are determined by the evidence presented, which in this case favored the respondents. On the irregularity of the writ of demolition: The Court noted that the propriety of the issuance of the writ of demolition was the subject of a separate petition for certiorari (Civil Case No. Q-98-33986) pending before the Regional Trial Court of Quezon City, Branch 217. Therefore, raising this issue in the present petition would constitute forum shopping, and the Supreme Court declined to rule on it in this instance.
Main Doctrine
In ejectment cases, the court may decide the issue of ownership if it is intertwined with the question of possession, as provided by Batas Pambansa Blg. 129 and Section 16, Rule 70 of the Rules of Court, to determine who has the better right to possess the property.