Miranda v. Besa
REITERATIONFacts
The Antecedents: Macaria Capuno owned two lots. On March 31, 1953, she sold a portion to Spouses Alejandro Miranda and Feliza Garcia. The Spouses Miranda had this portion surveyed, resulting in technical descriptions for a parcel of land of 289 square meters. In 1960, Macaria Capuno applied for the registration of the two lots, and the Spouses Miranda did not oppose. A title was issued to Capuno. On March 6, 1967, Capuno sold Lot 18 to Atty. Tomas Besa, who obtained a title. This property was subdivided and eventually, portions were sold to Circle Drug Corporation, and then to respondent Esperanza B. Besa, who obtained TCT No. 292806. Respondent Besa discovered that petitioner Lucia Miranda, daughter of the original vendees, occupied a portion of her property. Procedural History: On September 3, 1997, respondent Besa filed an unlawful detainer case against petitioner Miranda. The Municipal Circuit Trial Court (MCTC) ruled in favor of Besa, ordering Miranda to vacate and pay monthly rentals. The Regional Trial Court (RTC) affirmed the MCTC decision. The Court of Appeals (CA) affirmed the RTC decision with modification, deleting the award of attorney's fees, but directing Miranda to turn over possession and remove improvements. The Petition: Petitioner Miranda filed a petition for review on certiorari with the Supreme Court, raising issues regarding the jurisdiction of the ejectment court, the validity of the sale to her parents, her family's adverse possession, and the alleged defects in the complaint for failure to implead indispensable parties.
Issue(s)
Whether the MCTC, as a court of limited jurisdiction in an ejectment case, lost jurisdiction when the petitioner raised the issue of ownership. Whether the respondent's title to the property is valid and superior to the petitioner's claim based on a prior deed of sale. Whether the petitioner had acquired ownership of the property through acquisitive prescription. Whether the petitioner was guilty of estoppel and laches, or if the case was barred by res judicata. Whether the complaint for ejectment was defective for failure to implead indispensable parties.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed in toto.
Ratio Decidendi
On the issue of jurisdiction and the claim of ownership: The Court reiterated that in ejectment cases, the defendant cannot deprive the court of jurisdiction by simply claiming ownership. While the issue of ownership may be resolved to determine the issue of possession, such determination is not conclusive and is without prejudice to the parties ventilating their claims of ownership in a proper proceeding. The MCTC correctly exercised its jurisdiction as the issue of ownership was resolved only to determine the issue of possession. On the validity of the respondent's title and the petitioner's claim of prior sale: The Court held that the respondent, as the registered owner, had the right to possession. The petitioner's contention that the respondent's husband obtained title through fraud constituted a collateral attack on the title, which is not allowed. A certificate of title can only be challenged in a direct proceeding. On acquisitive prescription: The defense of acquisitive prescription, which goes into the issue of ownership, must be ventilated in a proper proceeding, not in an ejectment case. The respondent's title, being registered, can only be challenged in a direct action. On estoppel, laches, and res judicata: The Court noted that the appellate court found the petitioner guilty of estoppel and laches, and that the issue of ownership was already determined in prior cases, barring further claims under res judicata. These findings are factual and generally conclusive on the Supreme Court. On the failure to implead indispensable parties: The Court found the contention untenable. Indispensable parties are those without whom no final determination can be had. In this case, the petitioner's husband and siblings were not indispensable because their interest was distinct and divisible, and the judgment ordering the petitioner to vacate and remove improvements would not necessarily prejudice them, especially since the order included "successors-in-interest and members of her family."
Main Doctrine
In ejectment cases, the defendant cannot deprive the court of jurisdiction by merely claiming ownership; the issue of ownership may be resolved only to determine the issue of possession, and such determination is not conclusive.