Corpuz v. Agustin
REITERATIONFacts
The Antecedents: Ruben C. Corpuz (petitioner) filed an ejectment case against Spouses Hilarion and Justa Agustin (respondents) for two parcels of land. Petitioner claimed ownership based on a Deed of Quitclaim from his father, Francisco Corpuz, and a Transfer Certificate of Title (TCT) No. 12980 issued in his name. Respondents claimed ownership based on a Deed of Absolute Sale executed by Francisco Corpuz in their favor on June 5, 1971, for P11,150.00. Francisco Corpuz had previously sold the properties to Francisco D. Corpuz (father of Ruben) on August 27, 1951. Francisco D. Corpuz allowed respondents, who were relatives, to occupy the properties. Petitioner alleged that respondents refused to vacate despite demand. Procedural History: The Municipal Trial Court (MTC) dismissed the unlawful detainer case, finding that respondents occupied the properties as buyers/owners, not by mere tolerance, and had been in possession for a significant period. The Regional Trial Court (RTC), on appeal, affirmed the MTC's decision. The Court of Appeals (CA) also affirmed the dismissal, noting that petitioner's father engaged in a double sale. The Quitclaim to petitioner was dated March 15, 1971, and registered in 1976, leading to TCT No. T-12980. The Deed of Sale to respondents was dated June 5, 1971, but remained unregistered. The CA found that petitioner had knowledge of the sale to respondents as early as 1973 and that respondents' possession was in the exercise of ownership, not mere tolerance. The Petition: Petitioner filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's decision, primarily questioning who between him, as the registered owner, and the respondents, with an unregistered Deed of Absolute Sale, has the better right to possession.
Issue(s)
Whether the Court of Appeals erred in failing to consider the legal ownership of the petitioner on the disputed property to claim a better right to possession. Whether the Court of Appeals erred in the appreciation of the alleged sale in favor of respondents to rule that they have a better right to possession. Whether the Court of Appeals erred in failing to consider the case of Jacinto Co v. Militar, et al., which is similar to the instant case. Whether the Court of Appeals erred in denying the Petition for Review raised before it.
Ruling
The Supreme Court denied the Petition for lack of merit. The Decisions of the Court of Appeals, the Regional Trial Court, and the Municipal Trial Court, all dismissing the unlawful detainer case of petitioner, were affirmed.
Ratio Decidendi
On the issue of who has the better right to possession: The Court reiterated that in unlawful detainer cases, the primary issue is physical possession (possession de facto). While the Torrens title holder is generally entitled to possession, courts may pass upon the issue of ownership provisionally to determine the better right to possess. However, in this case, the respondents have been in continuous possession for over three decades, not by mere tolerance, but in the concept of ownership based on their Deed of Absolute Sale. The Court found that petitioner failed to prove that respondents' possession was by mere tolerance, a requisite for unlawful detainer. The Court noted that petitioner's claim of ownership through his Torrens title, while generally superior, cannot be used to dispossess respondents through a summary ejectment proceeding when their possession is established as being in the concept of ownership and not by mere tolerance. The Court also clarified that the respondents' claim of fraud against petitioner's title constitutes a collateral attack, which is impermissible in an unlawful detainer case. The Court emphasized that questions regarding the validity of the Torrens title must be ventilated in a direct proceeding. On the alleged sale in favor of respondents: The Court agreed with the CA that petitioner's father engaged in a double sale. While the Quitclaim to petitioner was executed before the Deed of Sale to respondents, the Quitclaim was registered later, and the Deed of Sale to respondents remained unregistered. The Court noted that petitioner had knowledge of the sale to respondents as early as 1973. However, the Court disagreed with the CA's conclusion that petitioner's failure to act was equivalent to registration of respondents' unregistered deed. The Court clarified that knowledge of a prior unregistered interest is equivalent to registration only if the prior interest existed at the time the party acquired their right. In this case, the Quitclaim to petitioner preceded the Deed of Sale to respondents, meaning the sale to respondents was not a prior interest when petitioner acquired his right. Nevertheless, this did not alter the outcome of the unlawful detainer case, as the core issue remained the nature of respondents' possession. On the applicability of Jacinto Co v. Militar, et al.: The Court acknowledged the similarity of the facts and legal issues in Jacinto Co v. Militar, et al., where it upheld the title holder's better right to possession. However, the Court distinguished the present case by highlighting that the respondents in Corpuz v. Agustin had been in possession for over thirty years, not by mere tolerance, but in the concept of ownership. This prolonged possession, coupled with the fact that the ejectment case was filed to dispossess them, made the summary remedy of unlawful detainer inappropriate, unlike in Jacinto Co, where the issue was more directly about the right to possession based on title versus unregistered sale without the same prolonged possessory claim. The Court of Appeals did not err in denying the Petition for Review raised before it because the core issue remained the nature of respondents' possession.
Main Doctrine
In an unlawful detainer case, while a registered owner is generally entitled to possession, the Court may provisionally pass upon ownership to determine the better right to possess. However, if the possessor claims ownership based on a sale and has been in possession for a long period, not by mere tolerance, an ejectment case may not be the proper remedy to dispossess them, especially if it involves a collateral attack on the title.