Malison v. Maranan
REITERATIONFacts
The Antecedents: The underlying dispute originated from a complaint filed by petitioners, Sps. Guillermo and Amelita Malison, against respondents, Sps. Melchor and Virginia Maranan, seeking the annulment of a document, quieting of title, and damages. The Regional Trial Court (RTC) dismissed the petitioners' complaint. Procedural History: Petitioners received the RTC Decision on April 19, 2002. Instead of filing a timely notice of appeal, they filed a manifestation on April 29, 2002, requesting a legible copy of the decision due to illegible pages. The RTC provided a legible copy on May 20, 2002. Petitioners then filed their Notice of Appeal on May 24, 2002. The Court of Appeals (CA), upon motion by respondents, dismissed the appeal as having been filed out of time, a ruling affirmed upon reconsideration. The Petition: Petitioners seek review of the CA's dismissal, arguing that the CA gravely abused its discretion by prioritizing technicality over substantial justice and by upholding the RTC's alleged misapprehension of facts and law. The core issue is the timeliness of their appeal. Petitioners contend that their initial receipt of an unreadable decision did not commence the reglementary period, and their subsequent filing of a manifestation should be considered a motion for reconsideration, thereby interrupting the appeal period. They argue that the CA erred in not giving due course to their appeal, which they believe was timely filed after receiving the legible copy of the decision.
Issue(s)
Whether the purchase of the subject property by respondents Sps. Maranan from a person other than the registered owner of a residential house and lot is valid; and whether the certificate of title under the Torrens System held by the private respondents can be collaterally attacked in an unlawful detainer action. Whether ejectment is the proper remedy of Sps. Maranan, assuming arguendo the validity of their title, considering the principles of possession de facto vs. de jure and the provisional nature of ownership determination in ejectment cases.
Ruling
The Supreme Court denied the petition for lack of merit and affirmed the decision of the Court of Appeals. The Court held that the factual findings of the CA, affirming those of the RTC, are conclusive. The Court reiterated that in ejectment cases, the issue is physical possession, and the determination of ownership is merely provisional. The validity of the title of private respondents, registered under the Torrens System, cannot be collaterally attacked in an unlawful detainer suit.
Ratio Decidendi
On the validity of the purchase and collateral attack on the title: The Court emphasized that a petition for review on certiorari under Rule 45 is limited to questions of law, and factual findings of the Court of Appeals, especially when affirming those of the trial court, are conclusive. The Court found that the factual findings were amply supported by evidence and thus conclusive. These settled facts included that the property was registered in Belen's name, she sold it through her attorney-in-fact to private respondents. Furthermore, the Court highlighted that a certificate of title under the Torrens System, like the one held by the private respondents, is presumed legal and cannot be collaterally attacked, especially in an unlawful detainer action. Such an issue can only be assailed in a direct proceeding for that purpose. On the propriety of ejectment: The Court clarified that ejectment cases, specifically unlawful detainer, are summary proceedings to recover possession where the defendant's possession was initially lawful but became illegal upon withdrawal of tolerance and refusal to vacate after demand. Petitioners occupied by tolerance, and they refused to vacate after demand. The MeTC had jurisdiction as the complaint sufficiently alleged unlawful withholding of possession by the registered owners and refusal to vacate despite demands. The complaint was filed within the one-year reglementary period. The Court reiterated the principle that in ejectment cases, the issue is possession de facto (physical possession), not possession de jure (legal possession), and the question of ownership is unessential, only to determine possession. The Court stressed that the determination of ownership in an ejectment case is merely provisional and does not bar a separate action to determine title. Therefore, the remedy of ejectment was properly availed of by the private respondents based on their allegations and the established facts regarding possession.
Main Doctrine
In ejectment cases, the primary issue is physical possession, not ownership. While ownership may be passed upon incidentally to determine possession, such determination is provisional and does not bind the title. A certificate of title under the Torrens System cannot be collaterally attacked in an ejectment suit.