Spouses Balanon-Anicete v. Balanon
REITERATIONFacts
The Antecedents: Respondent Pedro Balanon is the registered owner of a parcel of land in San Andres, Manila, on which a three-door apartment building was constructed. Respondent occupied Unit 2259, while petitioners Genoveva Balanon-Anicete and Filomena Balanon-Mananquil occupied Units 2261 and 2263, respectively. The petitioners are sisters of the respondent and are co-heirs of their deceased parents, Tiburcio and Alejandra Balanon. The petitioners dispute the respondent's sole ownership, alleging the land was purchased by their mother and the construction loan was paid with her pension funds, with the respondent fraudulently registering the property in his name. They claim their mother had previously filed an action for reconveyance, which was dismissed upon the respondent's promise to divide the property among the heirs. Procedural History: In April 1994, respondent Pedro Balanon filed separate unlawful detainer complaints against the petitioners before the Metropolitan Trial Court (MTC) of Manila, Branch 15, alleging they occupied the premises by his tolerance and refused to vacate despite demands. The MTC rendered a consolidated decision in favor of the respondent on August 19, 1994, ordering the petitioners to vacate and pay rent and attorney's fees. The petitioners appealed to the Regional Trial Court (RTC) of Manila, Branch 9, which affirmed the MTC decision in toto. Following the denial of their motion for reconsideration, the petitioners filed a petition for review with the Court of Appeals (CA), docketed as CA-G.R. SP No. 38739. The Petition: The Court of Appeals, in its decision dated October 5, 2001, denied the petitioners' petition for review and dismissed their motion for reconsideration. Unfazed, the petitioners filed the instant petition for review before the Supreme Court, arguing that the Court of Appeals erred in solely relying on the respondent's certificate of title without inquiring into the background of its acquisition and in ruling that the petitioners were possessors by mere tolerance. The petitioners contend that the ejectment cases should not be adjudicated solely on the basis of the respondent's evidence of ownership and that the issue of ownership should have been considered in light of the alleged fraudulent machinations in acquiring the title.
Issue(s)
Whether the Court of Appeals erred in upholding the respondent's right to eject petitioners based solely on his certificate of title without inquiring into the acquisition of the property, arguing that the respondent is not the true owner. Whether the petitioners were possessors by mere tolerance who have overstayed their permission, and whether the factual findings of lower courts on this matter are conclusive.
Ruling
The petition is denied. The decision of the Court of Appeals dated October 5, 2001, in CA-G.R. SP No. 38739, is affirmed in toto.
Ratio Decidendi
On the issue of relying on the certificate of title: The Court reiterated that in unlawful detainer cases, the sole issue is physical possession, independent of any claim of ownership. Even if ownership is raised, lower courts can only provisionally resolve it to determine possession, without prejudice to a separate action on ownership. The Court of Appeals correctly relied on the transfer certificate of title in the respondent's name. As the registered owner, respondent has the right to possession. Petitioners' argument that respondent is not the true owner constitutes a collateral attack on his title, which is impermissible in an ejectment suit. A certificate of title can only be challenged in a direct proceeding. On the issue of possession by tolerance: The Court found that the issue of whether petitioners' occupancy was by mere tolerance had been settled by the MTC, RTC, and CA. This is a question of fact, and the appellate court's factual findings are generally conclusive on the Supreme Court. The Court emphasized that persons occupying another's land by tolerance, without a contract, are bound by an implied promise to vacate upon demand, making summary ejectment the proper remedy.
Main Doctrine
In unlawful detainer cases, the issue of ownership can only be provisionally resolved for the sole purpose of determining possession, and such resolution does not bind the title or affect ownership. A certificate of title cannot be subject to collateral attack and can only be challenged in a direct proceeding.