Norberte v. Mejia
REITERATIONFacts
The Antecedents: The subject property was initially owned by Edgardo Ongsiaco, who allowed Dativa Gonzales to occupy it. Ongsiaco later sold the land to Spouses Legaspi, who registered it in their names and filed an ejectment case against Gonzales. On March 28, 1988, Spouses Legaspi executed a Deed of Conditional Sale over the property in favor of petitioners Spouses Norberte for P160,000.00. Spouses Norberte paid a downpayment, and the deed was notarized and annotated on the title. Procedural History: On July 6, 1990, Spouses Legaspi sold the same property to respondents Spouses Mejia, leading to a compromise agreement and dismissal of the ejectment case against Gonzales. Spouses Norberte filed an action to annul the sale to Spouses Mejia, which they won. On June 6, 2003, after paying the balance, Spouses Norberte obtained a Deed of Absolute Sale. They demanded Spouses Mejia vacate, and upon failure, filed an ejectment complaint on November 6, 2003, before the MeTC. The MeTC dismissed the case for lack of jurisdiction, finding the proper action should have been accion publiciana. The RTC affirmed the MeTC decision. The CA remanded the case to the RTC for further proceedings, reprimanding the counsel for Spouses Mejia for failing to provide the heirs' addresses. The CA denied Spouses Norberte's motion for reconsideration. The Petition: Spouses Norberte filed a petition for review, arguing that their action was for unlawful detainer, thus within the MeTC's jurisdiction, and that the Deed of Conditional Sale was a mere contract to sell.
Issue(s)
Whether the Metropolitan Trial Court (MeTC) had jurisdiction over the ejectment case filed by the Spouses Norberte. Whether the Deed of Conditional Sale executed on March 28, 1988, was a contract of sale or a contract to sell. Whether the death of the Spouses Mejia extinguished the ejectment action.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the jurisdiction of the MeTC: The Court sustained the finding that the MeTC lacked jurisdiction. Ownership of the property passed to the Spouses Norberte upon the execution of the Deed of Conditional Sale on March 28, 1988, through constructive delivery. The Court clarified that in summary ejectment suits, the sole issue is better possession, and these fall under the exclusive original jurisdiction of the first-level courts, provided they are filed within one year from loss of possession. An accion publiciana, however, is a plenary action to determine the legal right to possess and falls under the jurisdiction of the RTC, typically filed after the one-year period for ejectment has expired. Since the Spouses Norberte filed their ejectment complaint on November 6, 2003, more than one year after they were deemed to have acquired ownership and possession through constructive delivery on March 28, 1988, their action was filed beyond the prescriptive period for unlawful detainer. On the nature of the Deed of Conditional Sale: The Court held that the Deed of Conditional Sale was absolute in nature. The Court reiterated the principle that a deed of sale is absolute unless there is a stipulation reserving title to the seller until full payment. In this case, the Deed of Conditional Sale lacked any express reservation of title or ownership by the Spouses Legaspi. The absence of such a stipulation indicated that the parties intended an absolute sale, where ownership passes to the buyer upon delivery, actual or constructive. The condition mentioned in the deed pertained only to the performance of the parties' obligations, not to the transfer of ownership itself. On the survival of the ejectment action despite the death of the Spouses Mejia: The Court affirmed that the ejectment case survived the death of the Spouses Mejia. The Court explained that an ejectment case is not a purely personal action; therefore, it does not extinguish upon the death of a party. The heirs of the deceased respondents can take their place in the proceedings to protect and represent their interests. The Court also noted that Atty. Quimpo, counsel for the Spouses Mejia, should be reprimanded for failing to provide the court with the names and addresses of the legal representatives of the deceased spouses, despite the clear rule that the action survives.
Main Doctrine
A Deed of Conditional Sale, in the absence of an express stipulation reserving title to the seller until full payment, is considered absolute in nature, passing ownership to the buyer upon constructive delivery. If filed beyond one year from dispossession, an ejectment suit should be treated as an accion publiciana by the RTC.