Ejectment Actions: Possession Trumps Ownership (For Now)

G.R. No. 117005, June 19, 1997

Imagine you buy a property, excited to finally be a landlord. But one of the tenants refuses to leave, claiming the sale was invalid. Can you still evict them while the ownership dispute is being sorted out? This case clarifies that in ejectment suits, the immediate right to physical possession often takes precedence, even when questions of ownership are in the air.

Introduction

This case, Carlito D. Corpuz vs. Honorable Court of Appeals and Juanito Alvarado, revolves around a simple yet common scenario: a property owner seeking to evict a tenant. The twist? The tenant contested the validity of the sale that made Corpuz the owner. The Supreme Court had to determine whether an ongoing ownership dispute could halt an ejectment action.

The central legal question: Can a court hearing an ejectment case be forced to suspend proceedings while another case challenging the ownership of the property is pending in a different forum?

Legal Context: Understanding Ejectment and Jurisdiction

Ejectment cases, also known as unlawful detainer or forcible entry suits, are summary proceedings designed to quickly resolve disputes over physical possession of property. The primary goal is to restore possession to the party who is rightfully entitled to it, without delving into complex issues of ownership.

Philippine law grants Metropolitan Trial Courts (MTCs) exclusive jurisdiction over ejectment cases. This means that only MTCs can hear and decide these types of disputes. Section 33 (2) of Batas Pambansa Blg. 129, as amended by Republic Act 7691, explicitly states this jurisdictional grant.

A crucial concept in ejectment cases is possession de facto, which refers to actual physical possession of the property. Courts primarily focus on who has the right to possess the property at the moment, not necessarily who owns it. However, courts can look into evidence of ownership to determine the nature of the possession.

Key Provision: B.P. 129, Section 33(2) grants MTCs exclusive original jurisdiction in cases of unlawful detainer and forcible entry.

Example: Imagine a squatter occupies your land. Even if they claim ownership based on some dubious document, you can file an ejectment case to regain possession. The court will likely order their eviction, regardless of their ownership claim, unless they can prove a valid right to possess the property.

Case Breakdown: The Story of Corpuz vs. Alvarado

The dispute began when Lorenzo Barredo, the original owner of a property, decided to sell it to his tenants. Juanito Alvarado, one of the tenants, along with others, signed an “Affidavit of Waiver,” giving Barredo the right to sell to someone who could afford it. Carlito Corpuz eventually purchased the property. Corpuz then asked Alvarado to vacate the room he was occupying because his children needed it. Alvarado refused, leading to the ejectment suit.

Here’s a breakdown of the case’s journey through the courts:

• Metropolitan Trial Court (MTC): Ruled in favor of Corpuz, ordering Alvarado to vacate the premises.
• Regional Trial Court (RTC): Reversed the MTC’s decision, citing a pending case before the National Housing Authority (NHA) questioning the sale between Corpuz and Barredo. The RTC also deemed the “Affidavit of Waiver” a forgery.
• Court of Appeals: Affirmed the RTC’s decision, siding with Alvarado.
• Supreme Court: Overturned the Court of Appeals’ ruling, reinstating the MTC’s decision in favor of Corpuz.

The Supreme Court emphasized that the MTC has exclusive jurisdiction over ejectment cases and that suits for annulment of sale do not automatically stop ejectment actions. The Court quoted its earlier ruling in Refugia v. Court of Appeals, stating that inferior courts may look into evidence of title or ownership to determine the nature of possession, but cannot resolve the issue of ownership itself in an ejectment suit.

The Supreme Court stated:

“Clearly, the underlying reason for the above rulings is for the defendant not to trifle with the ejectment suit, which is summary in nature, by the simple expedient of asserting ownership thereon.”

The Court further noted that Alvarado could still pursue his case before the NHA to challenge the sale and assert his ownership rights. However, that did not prevent Corpuz from seeking immediate possession of the property through the ejectment suit.

Regarding the issue of referral to the Lupon Tagapayapa (barangay conciliation), the Court held that Alvarado waived this defense by not specifically alleging the lack of compliance with the Barangay conciliation procedure in his answer.

Practical Implications: What This Means for Landlords and Tenants

This case underscores the importance of understanding the distinct nature of ejectment suits. Landlords can pursue eviction even if ownership is contested, provided they can demonstrate a right to possess the property. Tenants, on the other hand, must understand that simply claiming ownership is not enough to prevent eviction; they must pursue separate legal actions to establish their ownership rights.

Key Lessons:

• Ejectment Suits Focus on Possession: The primary issue is who has the right to physical possession, not necessarily who owns the property.
• Ownership Disputes Don’t Automatically Stop Ejectment: A pending case challenging ownership does not automatically suspend an ejectment action.
• Pursue Separate Legal Actions: Tenants claiming ownership must file separate lawsuits to establish their rights.
• Comply with Barangay Conciliation: Properly raise the issue of non-compliance with Barangay conciliation procedures in your defense.

Hypothetical Example: You purchase a house, but the previous owner refuses to leave, claiming they never received full payment. You can still file an ejectment case to regain possession, even while the payment dispute is being litigated in another court. However, the ex-owner can also countersue for rescission of contract with damages.

Frequently Asked Questions

Q: What is an ejectment case?

A: An ejectment case is a legal action to recover possession of real property from someone who is unlawfully occupying it.

Q: What is the difference between unlawful detainer and forcible entry?

A: Unlawful detainer occurs when someone initially had lawful possession but refuses to leave after their right to possess has expired (e.g., after a lease ends). Forcible entry occurs when someone takes possession of property through force, intimidation, threat, strategy, or stealth.

Q: Can I be evicted if I claim to own the property?

A: Yes, you can be evicted in an ejectment case even if you claim ownership. The court will focus on who has the right to immediate physical possession. You must file a separate legal action to establish your ownership rights.

Q: What is the role of the Barangay in ejectment cases?

A: Before filing an ejectment case in court, you must generally attempt to resolve the dispute through Barangay conciliation. However, failure to comply with this requirement does not automatically invalidate the court’s jurisdiction.

Q: What should I do if I receive a notice to vacate?

A: Consult with a lawyer immediately. You may have legal defenses, such as challenging the validity of the notice or asserting your right to possess the property.

ASG Law specializes in real estate law and ejectment cases. Contact us or email hello@asglawpartners.com to schedule a consultation.