Asis v. Asis Vda. de Guevarra
REITERATIONFacts
The Antecedents: Respondent Consuelo Asis Vda. De Guevarra initiated separate ejectment cases against her brothers, Romeo, Oscar, and Eduardo Asis (petitioners), for unlawful detainer. Respondent claimed ownership of apartment units located on a parcel of land co-owned by her and her siblings. She alleged that petitioners were lessees who had stopped paying rent, despite repeated demands. Petitioners, in their defense, asserted co-ownership of both the land and the apartment units, claiming they inherited them from their parents who had constructed the units. They further contended that any payments made were contributions for the upkeep of the premises, not rentals. Procedural History: The Metropolitan Trial Court (MeTC) of Manila ruled in favor of the respondent, ordering the ejectment of the petitioners and payment of rental arrearages and attorney's fees. The Regional Trial Court (RTC) reversed this decision, finding that the MeTC lacked jurisdiction because the case involved not only possession but also the rights of the parties to the constructed buildings. The Court of Appeals (CA) subsequently reversed the RTC's ruling, reinstating the MeTC's decision. The CA held that the MeTC had jurisdiction to determine ownership provisionally for the purpose of resolving the issue of possession, and that the case cited by the RTC was not applicable. The Petition: Petitioners filed a petition for review on certiorari under Rule 45 of the Revised Rules of Court, seeking to overturn the CA's decision. They argued that the CA erred in reinstating the MeTC's decision, primarily contending that the Chua Peng Hian case applied because the respondent's complaint did not constitute a valid ejectment action, and that they could not be ejected as they were co-owners of the apartment units. The petition further argued that the MeTC lacked jurisdiction due to the intertwined issue of ownership with possession.
Issue(s)
Whether the Metropolitan Trial Court (MeTC) has jurisdiction over an unlawful detainer case where the issue of ownership is raised as a defense, and whether the primary issue is ownership or possession. Whether the petitioners, as alleged co-owners, can be ejected from the apartment units, considering the evidence presented by both parties regarding ownership and rental payments.
Ruling
The petition is DENIED. The Consolidated Decision dated March 7, 2000, rendered by the Metropolitan Trial Court of Manila, is hereby AFFIRMED.
Ratio Decidendi
On the jurisdiction of the MeTC in unlawful detainer cases involving ownership: The Supreme Court affirmed the jurisdiction of the MeTC. It reiterated the principle that in ejectment proceedings, the court may resolve the issue of ownership solely for the purpose of determining the issue of possession, as explicitly provided for in Section 16, Rule 70 of the 1997 Revised Rules of Civil Procedure. This power was expanded by Batas Pambansa Blg. 129. The Court clarified that the Chua Peng Hian case was not applicable. The Court emphasized that any pronouncement on ownership in such cases is provisional. The petitioners failed to prove that the primary issue was ownership rather than possession. On whether petitioners can be ejected as co-owners: The Court found no reversible error in the CA's affirmation of the MeTC's findings. The MeTC found sufficient basis for the eviction of the petitioners. The respondent presented evidence, such as loan records and tax declarations, supporting her claim of ownership over the apartment units, which the petitioners failed to refute with substantial evidence beyond their bare claim of co-ownership based on the principle of accession. The payments made by the petitioners were deemed by the MeTC to be rentals, supported by receipts, which the petitioners did not convincingly disprove. Therefore, the petitioners, as lessees who failed to pay rent, were validly ordered to vacate the premises.
Main Doctrine
In unlawful detainer cases, the Metropolitan Trial Court (MeTC) has jurisdiction even if the issue of ownership needs to be resolved to determine possession. Any pronouncement on ownership is provisional and does not bar a separate action to determine title. The jurisdiction of inferior courts in ejectment cases involving ownership was expanded by Batas Pambansa Blg. 129 and further clarified by the 1997 Revised Rules of Civil Procedure, Section 16, Rule 70.