Dizon v. Beltran
REITERATIONFacts
The Antecedents: Eddie E. Dizon and his deceased wife, Verona Juana Pascua-Dizon, were registered owners of a property in Davao City. In 2008, Verona filed a petition for protection orders against Eddie and their son, Bryan. The couple entered into a compromise agreement to sell the property for not less than P4,000,000.00, with proceeds to be divided equally. Verona died in December 2009. Shortly thereafter, Eddie discovered a Deed of Absolute Sale, dated December 1, 2009, conveying the property to Yolanda Vida P. Beltran for P1,500,000.00. Eddie alleged the Deed was falsified, with forged signatures of himself and Verona. Procedural History: In January 2010, Eddie filed civil and criminal cases against Beltran for nullification of the Deed and falsification. Beltran subsequently filed an unlawful detainer case against Eddie, Bryan, and others occupying the property. The Municipal Trial Court in Cities (MTCC) ruled in favor of Beltran, ordering the petitioners to vacate and pay rent, but also ordering Beltran to pay the remaining balance of the sale after deducting medical and burial expenses. The Regional Trial Court (RTC) reversed the MTCC decision, dismissing the unlawful detainer case, finding the Deed's signatures to be falsified and thus Beltran acquired no ownership. The Court of Appeals (CA) reversed the RTC, reinstating the MTCC decision and ordering the issuance of a writ of execution, finding that the issue of ownership could not be determined in an unlawful detainer case and that the petitioners failed to perfect their appeal by timely filing a supersedeas bond. The Petition: The petitioners, Eddie and Bryan Dizon, seek review via certiorari under Rule 45 of the Rules of Court, challenging the CA's decision and resolution. They argue that the CA erred in not upholding the RTC's finding that the MTCC could resolve the issue of ownership in an unlawful detainer case when the Deed of Sale was allegedly falsified. They contend that a falsified document cannot be the basis for an unlawful detainer action and that Beltran acquired no valid title. They also argue that the CA erred in ordering the execution of the MTCC judgment despite the pending issues of forgery and ownership, and that their posting of the supersedeas bond, though belated, should have been considered in light of the circumstances.
Issue(s)
Whether respondent Yolanda Vida P. Beltran has a cause of action for unlawful detainer against the petitioners, considering that the Deed of Absolute Sale she relied upon is allegedly falsified and void. Whether the Regional Trial Court correctly ruled that in an unlawful detainer case, the Municipal Trial Court in Cities can resolve the issue of ownership.
Ruling
The Supreme Court granted the petition, set aside the Court of Appeals' decision and resolution, and reinstated the Regional Trial Court's decision, thereby dismissing Yolanda Vida P. Beltran's complaint for unlawful detainer.
Ratio Decidendi
On the issue of unlawful detainer and the falsified Deed of Absolute Sale: The Court found merit in the petitioners' arguments. It reiterated the principle that while the issue of ownership may be resolved in an unlawful detainer case to determine possession, this is only a provisional determination. However, when the deed of sale itself is void and inexistent due to forgery, as alleged by the petitioners, the plaintiff has no right to possess the property. The Court noted that Eddie claimed he was abroad and Verona was unconscious when the Deed was executed, and that the Deed was pre-signed in April 2008. These circumstances, coupled with the prosecutor's finding of probable cause for falsification, reduced the Deed to a private instrument, stripping it of the presumption of regularity. Consequently, Vida acquired no right or title to the property through a void deed, and her complaint for unlawful detainer had no legal basis. The Court emphasized that a Torrens title does not serve as a shield for fraud, and registration of a property obtained fraudulently does not vest title. On the RTC's authority to resolve the issue of ownership: The Court agreed with the RTC that the issue of ownership could be resolved in the unlawful detainer case, but only to determine possession. The RTC's finding of forgery and invalidity of the Deed, based on a comparison of signatures and the discrepancy in the sale price, was a valid preliminary determination for the purpose of resolving possession. The Court clarified that such adjudication of ownership in an ejectment case is provisional and does not bar a separate action involving title. The CA erred in concluding that the RTC made a conclusive finding on ownership and that the petitioners' challenge constituted a collateral attack on Vida's title. The Court cited Consolacion D. Romero and Rosario S.D. Domingo v. Engracia D. Singson to support the proposition that a void title can be attacked collaterally, and that a forged instrument cannot confer ownership. The Court also found that the circumstances surrounding the Deed, including the alleged defective notarization and the subsequent finding of probable cause for falsification, warranted a higher level of scrutiny than that afforded to a duly notarized public document, requiring proof by preponderance of evidence.
Main Doctrine
In an unlawful detainer case, the issue of ownership may be resolved only to determine the issue of possession. However, if the deed of sale relied upon is void and inexistent due to forgery, the complaint for unlawful detainer must be dismissed as the plaintiff has no right to possess the property.