Alco Business Corp. v. Abella
REITERATIONFacts
The Antecedents: Petitioner Alco Business Corporation (ABC) filed a forcible entry case against respondents, claiming ownership of two parcels of land in Quezon City based on Transfer Certificate of Title (TCT) Nos. 574662 and 253304. ABC alleged that respondents illegally occupied the land through force and stealth. Respondents countered that ABC's titles were fictitious and that they occupied the land with the consent of the heirs of the original owners, spouses Blas Fajardo and Pantaleona Santiago, whose claim was based on Original Certificate of Title (OCT) No. 56 and Decree No. 1275. The heirs had filed a petition for reconstitution of OCT No. 56. Procedural History: The Metropolitan Trial Court (MeTC) ruled in favor of ABC. On appeal, the Regional Trial Court (RTC) reversed the MeTC decision, dismissing ABC's complaint after finding its titles to be spurious. The Court of Appeals (CA) sustained the RTC's decision, agreeing that ABC's titles were untrustworthy or dubious, and thus ABC had no right to eject respondents. The Petition: ABC filed a petition for review on certiorari with the Supreme Court, questioning the CA's decision to sustain the RTC's reversal based on evidence not formally introduced in the trial court and for holding ABC's titles void and spurious in an ejectment case.
Issue(s)
Whether the Court of Appeals may sustain the Regional Trial Court in reversing the Decision of the Metropolitan Trial Court based on evidence not formally introduced as evidence in the trial court. Whether the Court of Appeals may sustain the Regional Trial Court in holding in an ejectment case that the titles of petitioner are void and spurious.
Ruling
The petition is DENIED for lack of merit. The Court sustained the Court of Appeals' decision affirming the Regional Trial Court's dismissal of the forcible entry case.
Ratio Decidendi
On the issue of evidence not formally introduced: The Court held that the RTC and CA did not err in considering the evidence presented. The RTC and CA mainly relied on the transfer certificates of title submitted by petitioner before the trial court, namely, TCT No. RT-5835 (247313) in the name of Teresita P. Visconde, petitioner’s predecessor-in-interest; TCT No. RT-3453 (253304) in the name of petitioner; and the Resolution of the Department of Justice dated July 9, 1990 in I.S. No. 89-00010, which was a public document annexed to respondents’ Answer. Therefore, there was nothing irregular in the assessment of evidence by the appellate courts. On the issue of holding titles void and spurious in an ejectment case: The Court reiterated that in forcible entry and unlawful detainer cases, if the defendant raises the question of ownership and the issue of possession cannot be resolved without deciding ownership, inferior courts and the Court of Appeals have the competence to provisionally resolve the issue of ownership solely for the purpose of determining possession. In this case, petitioner's cause of action for forcible entry was grounded on its alleged ownership, which was disputed by respondents. Petitioner failed to discharge its burden to show a right of possession because its alleged right was based on transfer certificates of title that were found to be unreliable due to discrepancies in their technical descriptions. Consequently, the action for forcible entry could not prosper.
Main Doctrine
In forcible entry and unlawful detainer cases, if the defendant raises the question of ownership and possession cannot be resolved without deciding ownership, inferior courts and the Court of Appeals may provisionally resolve ownership solely to determine possession. A plaintiff in a forcible entry case must prove a right of possession, which cannot be based on spurious titles.