Heirs of Hernandez v. Vergara
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the possession of a property located at 1110 Sulu Street, Sta. Cruz, Manila. The deceased owner, Basilisa Hernandez, had allowed the respondent, Bernardo Vergara, Jr., and his family to occupy the property by mere tolerance, with the understanding that he would maintain it and return it upon demand. Following Basilisa's death, her heirs, the petitioners, demanded the return of the property. The respondent refused, claiming ownership by virtue of a deed of donation inter vivos executed when he was a child. 2. Procedural History: The petitioners initiated an ejectment suit before the Metropolitan Trial Court (MeTC) of Manila, Branch 8. The MeTC ruled in favor of the petitioners, ordering the respondent's ejectment. This decision was affirmed by the Regional Trial Court (RTC), Branch 20. However, the Court of Appeals (CA), in its Decision dated July 30, 2004, reversed the lower courts' rulings, dismissing the ejectment case. The CA found that the issue of ownership was inextricably linked to possession and that the MeTC lacked jurisdiction to resolve such a complex ownership claim in a summary ejectment proceeding, suggesting an accion reinvindicatoria was the proper remedy. The CA subsequently denied the petitioners' motion for reconsideration. 3. The Petition: The petitioners seek a reversal of the CA's decision and resolution through a petition for review on certiorari under Rule 45 of the Rules of Court. They argue that the MeTC retains jurisdiction over ejectment cases even when the defendant raises the issue of ownership, provided that the primary claim is for possession and the ownership issue is only resolved provisionally to determine possession. They contend that the CA misappreciated the nature of ejectment cases and the relevant jurisprudence, particularly in light of the respondent's claim of ownership being raised only in his answer, not as the primary basis of the petitioners' complaint for ejectment.
Issue(s)
Whether the Metropolitan Trial Court (MTC) has jurisdiction over an ejectment case when the defendant raises the issue of ownership, which is intertwined with the issue of possession. Whether the Court of Appeals erred in dismissing the ejectment case and suggesting an accion reinvindicatoria as the proper remedy.
Ruling
The petition is granted. The Decision and Resolution of the Court of Appeals are annulled and set aside. The reversed MeTC and RTC decisions are reinstated and affirmed, ordering the ejectment of the respondent and payment of attorney's fees and costs.
Ratio Decidendi
On the jurisdiction of the MTC in ejectment cases involving ownership: The Court reiterated the settled doctrine that ejectment cases fall within the jurisdiction of the MTC, regardless of whether ownership is raised or if possession cannot be determined without resolving ownership. Section 33 of Batas Pambansa Blg. 129, as amended, and Section 18, Rule 70 of the 1997 Rules of Civil Procedure, as amended, clearly grant this jurisdiction. The MTC's judgment on ownership in such cases is provisional and solely for determining possession, not binding on the title or ownership itself. Therefore, the CA erred in ruling that the MTC was divested of jurisdiction. On the propriety of the ejectment suit: The Court found that the CA's reliance on Sedoncillo vs. Benolirao and Refugia vs. Court of Appeals was misplaced. In Refugia, it was clarified that inferior courts have jurisdiction to resolve ownership as an incident in ejectment cases provided that the primary relief sought is the restoration of possession. In this case, the petitioners' complaint clearly sought possession based on Bernardo's alleged possession by mere tolerance, not recovery of ownership. The issue of ownership was raised by Bernardo in his Answer, not as the primary claim of the petitioners. Thus, the action was indeed an ejectment suit, not an accion reinvindicatoria.
Main Doctrine
In ejectment cases, the Metropolitan Trial Court (MTC) has jurisdiction to resolve the issue of ownership when it is intertwined with possession, but the determination of ownership is provisional and solely for the purpose of resolving the issue of possession, and does not bind the title or affect ownership.