Garcia v. Zosa
REITERATIONFacts
The Antecedents: Respondent Teofilo D. Zosa, Jr. filed a complaint for forcible entry against petitioner Demetria Garcia with the Metropolitan Trial Court (MTC) of Antipolo City. Respondent alleged that he purchased Lot No. 2, Psu-215665 from petitioner on August 21, 1972, as evidenced by a Deed of Sale. He further alleged that in March 1995, petitioner, through force, stealth, and strategy, entered the lot and constructed a house thereon, depriving him of possession. Petitioner denied the allegations, claiming ownership and prior possession of the lot since before World War II. She asserted that she sold Lot No. 2, Psu-185191, not the lot in question, and that the Deed of Sale did not reflect the true intent of the parties. Procedural History: The MTC ruled in favor of the respondent, ordering petitioner to vacate the property, pay monthly rentals, attorney's fees, and costs. The MTC found that the lot in controversy was the same lot sold to the respondent. On appeal, the Regional Trial Court (RTC) reversed the MTC decision, dismissing the complaint. The RTC held that the MTC lacked jurisdiction because the issue of ownership was raised, and possession could not be determined without resolving ownership, which is beyond the MTC's jurisdiction. The Court of Appeals, in turn, reversed the RTC decision, reinstating the MTC ruling. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for review on certiorari with the Supreme Court, assailing the Court of Appeals' decision, primarily questioning its ruling on the MTC's jurisdiction over the forcible entry case.
Issue(s)
Whether the Court of Appeals erred in ruling that the MTC has jurisdiction over the forcible entry case despite the issue of ownership being raised. Whether the lot subject of the controversy is the same lot sold by the petitioner to the respondent.
Ruling
The petition is DENIED. The assailed Decision and Resolution of the Court of Appeals in CA-G.R. SP No. 48107 are AFFIRMED. Costs against petitioner.
Ratio Decidendi
On the issue of MTC jurisdiction over forcible entry cases involving ownership: The Court reiterated that Metropolitan Trial Courts (MTCs) have exclusive original jurisdiction over cases of forcible entry and unlawful detainer, as provided in Section 33(2) of Batas Pambansa Blg. 129, as amended. This jurisdiction is maintained even when the defendant raises the question of ownership in their pleadings. The proviso in the law clarifies that when possession cannot be resolved without deciding ownership, the issue of ownership shall be resolved solely for the purpose of determining possession. This is further supported by Section 18, Rule 70 of the 1997 Rules of Civil Procedure, which states that the judgment in ejectment cases is conclusive only with respect to possession and does not bind the title or affect ownership. The Court emphasized that its previous rulings consistently uphold the MTC's jurisdiction in such cases, regardless of the ownership question. The judgment on ownership in these cases is provisional and does not preclude a separate action to determine title. Therefore, the Court of Appeals did not err in holding that the MTC has jurisdiction to hear and decide the forcible entry case, notwithstanding the petitioner's assertion of ownership. On the identity of the lot sold: The Court found no reason to deviate from the findings of the MTC and the Court of Appeals, which both concluded that the lot subject of the respondent's complaint was indeed the same lot sold to him by the petitioner. This factual finding, affirmed by the appellate court, is given great weight and is not ordinarily disturbed by the Supreme Court in a petition for review on certiorari. The MTC's determination that the property in dispute was the one covered by the Deed of Sale was a factual conclusion based on the evidence presented during the trial.
Main Doctrine
The Metropolitan Trial Courts (MTC) have exclusive original jurisdiction over cases of forcible entry, and this jurisdiction is not divested even if the defendant raises the question of ownership, provided that the issue of ownership is resolved only to determine the issue of possession.