Salandanan v. Mendez
REITERATIONFacts
The Antecedents: Respondents, Spouses Mendez, filed a complaint for ejectment against Spouses Fernandez for the subject property, alleging ownership via a deed of donation and Transfer Certificate of Title (TCT) No. 246767. Spouses Fernandez claimed ownership by Spouses Pablo and Sofia Salandanan, alleging fraud in the transfer of title to Spouses Mendez and that a separate case for annulment of title was pending. The MeTC ruled in favor of Spouses Mendez, ordering Spouses Fernandez to vacate and pay rentals and attorney's fees. The RTC affirmed the MeTC decision and ordered execution pending appeal due to non-payment of rentals. During the sheriff's attempt to implement the writ, petitioner Sofia Aniosa Salandanan, an elderly woman, was found inside the premises, allegedly placed there by Spouses Fernandez to elicit pity. The CA affirmed the RTC decision, ordering Spouses Fernandez and all persons claiming rights under them, including petitioner, to vacate. Procedural History: The MeTC ruled in favor of respondents. The RTC affirmed the MeTC decision and ordered execution pending appeal. The CA affirmed the RTC decision. Petitioner filed a Motion for Clarification and Intervention, which was denied by the CA, stating that intervention was belated and her rights could be protected in a separate proceeding. The CA also denied the motion for reconsideration of Spouses Fernandez. The Petition: Petitioner seeks to annul the CA's decision and resolution, arguing grave abuse of discretion for including her in the judgment without due process, denying her motion for intervention, failing to consider the issue of ownership, and not suspending the case despite equitable circumstances.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction when it included petitioner in its adverse judgment in violation of her constitutional right to due process. Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction when it denied the motion for intervention by petitioner. Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction when it did not take into account the issue of ownership in resolving the issue of who has better possession. Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction when it did not suspend the case despite the equitable circumstances present in the case at bar.
Ruling
The petition is denied. The assailed Decision of the Court of Appeals dated June 27, 2003, affirming the decision of the Regional Trial Court, and its Resolution dated September 3, 2003, denying the petition for clarification and intervention filed by Sofia Aniosa Salandanan, are affirmed.
Ratio Decidendi
On the issue of inclusion in the judgment and due process: The Court held that while a judgment in an ejectment suit is generally in personam, it can bind non-parties under certain exceptions. Petitioner, being a relative and privy to Spouses Fernandez, and allegedly acting as their agent to frustrate the judgment by occupying the property after the writ of execution was ordered, falls under these exceptions. The Court noted that Spouses Fernandez never alleged petitioner's actual possession prior to the proceedings and that she was allegedly brought to the premises by Spouses Fernandez to plead for mercy. Furthermore, Spouses Fernandez admitted in their petition for review that petitioner took possession only after the RTC denied the motion for reconsideration of the writ of execution, indicating her actions were to frustrate the judgment. On the denial of the motion for intervention: The Court reiterated that intervention is generally allowed before rendition of judgment by the trial court. Petitioner's motion was filed after the CA rendered its decision, making it belated. The Court emphasized that ejectment cases are summary proceedings designed for expeditious restoration of possession and should not be delayed. Moreover, the issue of ownership raised by petitioner cannot be fully adjudicated in an ejectment case, as judgments in such cases are conclusive only with respect to possession and do not bind the title or ownership. Since petitioner had already filed a separate case for annulment of title, her rights could be fully protected in that proceeding, thus justifying the denial of intervention. On the failure to consider the issue of ownership: The Court reiterated that ejectment cases are primarily concerned with who has the better right to physical possession, not ownership. The issue of ownership is a separate matter that should be threshed out in a different proceeding, such as the annulment of title case already filed by petitioner. The Court noted that the lower courts consistently found that respondents had the Torrens Title to the property, which serves as the best proof of their right to possess, and this finding is generally conclusive on appeal, especially when affirmed by the CA. The Court cited Malison v. Court of Appeals to emphasize that in ejectment cases, the question of ownership is not the primary issue, and even a questionable title does not prevent the resolution of possession. On the failure to suspend the case: The Court found no merit in the argument that the case should have been suspended due to the pending annulment of title case. The Court reiterated the summary nature of ejectment proceedings, which are designed for speedy resolution of possession disputes. Allowing suspension would defeat the purpose of these actions and cause undue delay. The Court also pointed out that petitioner's claim of ownership was not fully established in the ejectment case, and the presumption of legality of respondents' Torrens Title supported the lower courts' ruling in favor of respondents' right to possession.
Main Doctrine
In ejectment cases, the issue of ownership cannot be definitively resolved, as the primary concern is the determination of who has the better right to physical possession. Intervention after judgment is generally not allowed if the intervenor's rights can be fully protected in a separate proceeding, especially when such intervention would unduly delay the summary nature of ejectment actions. A judgment in an ejectment suit, while generally in personam, may bind non-parties who are agents, members of the family, or privies of the defendant, especially if their actions are designed to frustrate the judgment.