Go Ke Chong v. Chan
REITERATIONFacts
The Antecedents: Petitioner Go Ke Chong, Jr. filed a complaint for forcible entry against respondent Mariano M. Chan, alleging that respondent's men illegally fenced off Lot No. 553, an area of 110 sq m, and demolished petitioner's building and improvements thereon. Petitioner claimed ownership and possession of the lot since January 15, 1998, asserting he had lawfully occupied and developed it as idle public land. Respondent countered that the disputed property is part of a larger lot he inherited, that he had leased the property to petitioner, and that petitioner's claim of ownership was a surreptitious attempt to retain the property after the lease expired. Respondent also noted a pending case for quieting of title between the parties. Procedural History: The Municipal Trial Court in Cities (MTCC), Branch 1, San Fernando, La Union, initially granted petitioner's prayer for a writ of preliminary injunction. However, on April 1, 2002, the MTCC dismissed petitioner's complaint for forcible entry, ruling it lacked jurisdiction because the issue of possession was intertwined with the issue of ownership, which it deemed beyond its competence. The MTCC cited a pending case for quieting of title before the Regional Trial Court (RTC) as further support. Petitioner's motion for reconsideration was denied on May 22, 2002. The Petition: Petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, arguing that the MTCC gravely erred in dismissing the forcible entry case for lack of jurisdiction. He contended that the MTCC should have provisionally resolved the issue of ownership to determine possession and that the respondent's claims of ownership were unsubstantiated. Petitioner asserted that the MTCC's decision involved questions of law and misapprehension of facts, and prayed for the reversal of the MTCC's decision and order, a declaration of his prior possession, and the remand of the case for trial on the merits.
Issue(s)
Whether the Municipal Trial Court (MTCC) erred in dismissing the forcible entry case on the ground of lack of jurisdiction. Whether the MTCC has the competence to provisionally resolve the issue of ownership in an ejectment case for the sole purpose of determining possession.
Ruling
The Supreme Court granted the petition, reversed and set aside the Decision and Order of the MTCC, and remanded the case to the MTCC for proper resolution on the merits.
Ratio Decidendi
On Whether the MTCC erred in dismissing the forcible entry case on the ground of lack of jurisdiction: The Supreme Court held that the MTCC erred in dismissing the petitioner's complaint for forcible entry on the ground of lack of jurisdiction. The Court reiterated its settled doctrine that even when the issues of ownership and possession de facto are intricately interwoven, this fact will not cause the dismissal of a forcible entry or unlawful detainer case based on jurisdictional grounds. The Court emphasized that in such cases, the Metropolitan Trial Court (MTC) has the undoubted competence to provisionally resolve the issue of ownership for the sole purpose of determining the issue of possession. This provisional resolution of ownership does not bar or prejudice a separate action between the same parties involving title to the property. The MTCC's reliance on older jurisprudence that held otherwise was deemed erroneous as those decisions had been abandoned by more recent rulings. On Whether the MTCC has the competence to provisionally resolve the issue of ownership in an ejectment case for the sole purpose of determining possession: The Supreme Court affirmed that inferior courts, by virtue of Batas Pambansa Blg. 129, have jurisdiction to resolve the question of ownership raised as an incident in an ejectment case where a determination thereof is necessary for a proper and complete adjudication of the issue of possession. The Court clarified that the passage of Batas Pambansa Blg. 129 led to jurisprudence that seemingly conflicted on the matter, but the Court definitively ruled that MTCs have jurisdiction to hear and decide forcible entry and unlawful detainer cases regardless of whether they involve questions of ownership or if the issue of possession cannot be determined without resolving the question of ownership. This ruling is subject to the condition that the lower court's adjudication of ownership is merely provisional.
Main Doctrine
In forcible entry and unlawful detainer cases, even if the issue of possession cannot be resolved without deciding the issue of ownership, the Metropolitan Trial Court (MTC) has jurisdiction to provisionally resolve the issue of ownership for the sole purpose of determining the issue of possession. The MTC's adjudication of ownership in such cases is merely provisional and does not bar a separate action involving title to the property.