The Supreme Court clarified the jurisdictional requirements for unlawful detainer cases, ruling that a complaint sufficiently establishes jurisdiction in the Municipal Trial Court (MTC) when it alleges unlawful withholding of possession, even if ownership is disputed. This decision reinforces the principle that ejectment cases focus on possession de facto, not ownership, and that mere claims of ownership do not oust the MTC of its jurisdiction.

Ejectment or Ownership Dispute: When Does an Unlawful Detainer Case Hold Water?

This case arose from an ejectment complaint filed by Ross Rica Sales Center, Inc. and Juanito King & Sons, Inc. (petitioners) against Spouses Gerry and Elizabeth Ong (respondents) before the MTC of Mandaue City. Petitioners claimed ownership of three parcels of land previously owned by respondent Elizabeth Ong. After petitioners demanded that respondents vacate the property, the latter refused, leading to the ejectment suit. Respondents, however, argued that the MTC lacked jurisdiction because the case was essentially an accion reivindicatoria (an action for recovery of ownership), which falls under the jurisdiction of the Regional Trial Court (RTC). They claimed they were the rightful owners and that petitioners’ claim was based on a disputed title.

The central legal question was whether the allegations in the complaint met the jurisdictional requirements for an unlawful detainer case, properly cognizable by the MTC, or whether it was actually an action for recovery of ownership, which should be filed in the RTC. This distinction is critical because it determines which court has the authority to hear and decide the case, and ultimately, who has the right to possess the property.

The Supreme Court held that the MTC had jurisdiction over the ejectment complaint. The Court emphasized that the nature of an action is determined by the allegations in the complaint and the character of the relief sought. Here, petitioners alleged that they were the registered owners of the lots and that respondents were unlawfully withholding possession despite demands to vacate. These allegations, the Court found, sufficiently established the elements of an unlawful detainer case.

The Court rejected the argument that the case was an accion reivindicatoria. The Court explained the key difference between these actions: accion reivindicatoria concerns recovery of ownership, while unlawful detainer focuses on the right to possess. In unlawful detainer cases, the issue of ownership is secondary to the question of possession. The court noted the differences among actions involving real property.

Specifically:

• Accion reivindicatoria: Action to recover ownership of real property.
• Accion publiciana: Action for the better right of possession (possession de jure).
• Accion interdictal: Action for material possession (possession de facto), encompassing forcible entry and unlawful detainer.

Building on this principle, the Court emphasized that the assertion of ownership as a defense in an ejectment case does not automatically transform the action into one for recovery of ownership. This is because the MTC’s jurisdiction is determined by the nature of the complaint, not the defenses raised. As long as the complaint alleges unlawful withholding of possession, the MTC retains jurisdiction to hear the case.

Furthermore, the Supreme Court underscored that a certificate of title is generally indefeasible and not subject to collateral attack. The validity of the respondents’ title could only be challenged in a direct proceeding specifically instituted for that purpose. Here, such proceeding for declaration of nullity of deed of sale and Transfer Certificates of Title and quieting of title in Civil Case No. MAN-2356 will not abate the ejectment case. Thus, the court cannot rule on the validity of a title in an ejectment case. To illustrate, the court reiterated Sec. 48 of Presidential Decree No. 1529, also known as the Land Registration Act, which states:

“A certificate of title shall not be subject to collateral attack. It cannot be altered, modified, or cancelled, except in a direct proceeding for that purpose in accordance with law.”

In closing, it becomes evident that the Court gave premium to the fact that what was prayed for is ejectment or recovery of possession, and it does not matter if ownership is claimed by either party. The bottom line, the MTC correctly assumed jurisdiction, and that the appellate court was incorrect in taking a contrary position.

FAQs

What was the key issue in this case?	The key issue was whether the MTC had jurisdiction over the ejectment complaint filed by the petitioners against the respondents, or whether the case was actually an accion reivindicatoria falling under the RTC’s jurisdiction.
What is unlawful detainer?	Unlawful detainer is a legal action to recover possession of property from someone who initially had lawful possession but whose right to possess has expired or terminated. It focuses on possession de facto, not ownership.
What is accion reivindicatoria?	Accion reivindicatoria is a legal action to recover ownership of real property. The main issue is ownership, not merely possession.
Does claiming ownership as a defense in an ejectment case change the court’s jurisdiction?	No, the assertion of ownership as a defense does not automatically oust the MTC of its jurisdiction. The nature of the action is determined by the allegations in the complaint, not the defenses raised.
What must be alleged in a Complaint to be considered an action for unlawful detainer?	The Complaint must sufficiently alleged that the defendant is unlawfully withholding possession of the property from the plaintiff after the expiration or termination of the right to hold possession. The complaint needs to state that despite demand to vacate, the defendant refuses to do so, thus unlawfully withholding possession of said lots from plaintiffs.
Can a certificate of title be challenged in an ejectment case?	No, a certificate of title cannot be collaterally attacked in an ejectment case. It can only be challenged in a direct proceeding specifically instituted for that purpose.
What is the significance of possession de facto in ejectment cases?	Possession de facto, or actual physical possession, is the central issue in ejectment cases. The court focuses on who has the right to physical possession, regardless of ownership claims.
What happens if there is a pending case about the title of the same property?	Even if there is a pending case regarding the title or ownership of the property, the ejectment case can proceed separately. The decision in the ejectment case is provisional and does not bar a subsequent action involving title.

In summary, this case clarifies that the MTC retains jurisdiction over unlawful detainer cases even when ownership is contested, reinforcing the summary nature of ejectment proceedings and the focus on possession de facto. This ruling ensures that property owners can quickly recover possession of their land without being unduly delayed by protracted ownership disputes.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Ross Rica Sales Center, Inc. vs Spouses Gerry Ong, G.R No. 132197, August 16, 2005