Go v. Looyuko
REITERATIONFacts
The Antecedents: Respondent Alberto T. Looyuko (Looyuko) and Jimmy Go, brother of petitioner William Go (William), were partners in Noah’s Ark Group of Companies (Noah’s Ark). William was allowed by Looyuko to occupy a townhouse in Gilmore Townhomes, Quezon City, where he was appointed Chief of Staff of Noah’s Ark Sugar Refinery. In 1998, Looyuko demanded that William vacate the townhouse. Jimmy Go filed an adverse claim over the property, asserting it was bought using partnership funds and thus part of the partnership’s assets. William refused to vacate, relying on his brother's adverse claim. Procedural History: Looyuko filed an unlawful detainer case against William before the Metropolitan Trial Court (MeTC). The MeTC ruled in favor of Looyuko, recognizing his right to possession as the registered owner. William appealed to the Regional Trial Court (RTC), which deferred proceedings pending the outcome of a separate specific performance case filed by Jimmy Go to establish his co-ownership claim. The RTC eventually ruled in favor of William, finding that the property was purchased in the name of Noah’s Ark and Looyuko held title for expediency. Looyuko appealed to the Court of Appeals (CA), which reversed the RTC decision, reinstating the MeTC ruling and holding that possession could be resolved without ruling on ownership, as Looyuko’s TCT unequivocally showed his ownership and entitlement to possession. William’s motion for reconsideration was denied. The Petition: William filed a petition for review on certiorari with the Supreme Court, arguing that the CA erred in holding that the ejectment case could proceed without resolving the issue of ownership, and that the QC RTC correctly appreciated the evidence showing Noah’s Ark as the actual owner and his occupancy as a privilege. He also contended that Looyuko failed to prove prior physical possession.
Issue(s)
Whether the Court of Appeals erred in holding that the ejectment case could proceed without resolving the issue of ownership raised by the petitioner. Whether the Court of Appeals erred in granting the petition for review and reversing the Regional Trial Court's decision.
Ruling
The petition is DENIED. The Court affirmed the decision of the Court of Appeals, reinstating the Metropolitan Trial Court's decision in favor of Looyuko. The unlawful detainer case is decided based on the registered owner's right to possession, without prejudice to the outcome of the separate civil case concerning ownership claims between Jimmy Go and Looyuko.
Ratio Decidendi
On the issue of whether the ejectment case can proceed without resolving the issue of ownership: The Court held that while the issue of ownership should be ruled upon when it is inextricably linked to possession, as in this case, the resolution of ownership in an unlawful detainer case is merely provisional and for the purpose of determining possession. The Court reiterated its consistent stance in upholding the registered owner's superior right to possess the property. The existence of a Torrens Title is considered evidence of indefeasible title and entitles the holder to possession as a matter of right. The partnership agreements and other documentary evidence presented by the petitioner were deemed insufficient to offset the respondent's right as the registered owner. This adjudication on ownership does not bar or prejudice the separate action between Jimmy Go and Looyuko concerning their claimed shares in the title over the property. The Court emphasized that the validity of the title could be assailed in a direct proceeding, not in an ejectment action. The Court also clarified that prior physical possession by the plaintiff is not an indispensable requirement in an unlawful detainer case, citing Section 1 of Rule 70 of the Rules of Court, which outlines the requirements for filing such an action. The focus remains on the unlawful withholding of possession after the termination of the right to hold it. On the issue of whether the Court of Appeals erred in granting the petition for review and reversing the Regional Trial Court's decision: The Court found no cogent reason to reverse the CA's findings. The Court reiterated that a petition for review under Rule 45 is limited to questions of law, and questions of fact, such as the reevaluation of evidence, are not reviewable. Even if the Court were to reevaluate the evidence, considering the divergent positions of the lower courts, the petition would still fail. The Court agreed with the CA that the TCT of respondent Looyuko unequivocally showed his ownership and, as a consequence, his entitlement to possession. The Court stressed that the registered owner's right to possess is superior and cannot be collaterally attacked in a mere action for unlawful detainer. The Court concluded that the CA correctly applied the established jurisprudence on unlawful detainer cases.
Main Doctrine
In unlawful detainer cases, the registered owner's title, evidenced by a Torrens Title, grants them the superior right to possess the property, and this right cannot be collaterally attacked, especially when the issue of ownership is inextricably linked to possession. Prior physical possession by the plaintiff is not an indispensable requirement for an unlawful detainer action.