G.R. No. 109312 and G.R. No. 120245. March 29, 1996.
HEIRS OF PLACIDO MIRANDA, et al., petitioners, vs. THE COURT OF APPEALS, HON. RODOLFO TOLEDANO, et al., respondents. ISMAEL ESMELE, et al., petitioners, vs. THE COURT OF APPEALS, HON. FELIX MAMENTA, JR., et al., respondents.

FACTS

These consolidated cases involve a 21-hectare land in Palauig, Zambales. The land, originally owned by Placido Miranda, was administered by his son Maximo upon Placido’s death. On November 5, 1957, Maximo sold the land to Agerico Miranda. A Free Patent Title was later issued in 1984 to Agerico’s daughter, Charito Miranda. Private respondents, representing Charito, possessed and cultivated the land from 1957 onward.
In G.R. No. 109312 , the heirs of Placido Miranda filed a complaint in 1992 for annulment of the 1957 sale and reconveyance, alleging fraud and that Charito, as a foreign citizen, was disqualified to own land. The Regional Trial Court dismissed the complaint on the ground of prescription, a dismissal affirmed by the Court of Appeals. In G.R. No. 120245, stemming from the same property, private respondents filed an ejectment case after the heirs entered the land in December 1991. The Municipal Circuit Trial Court ruled for private respondents, a decision affirmed by the RTC and the Court of Appeals.

ISSUE

The primary issues are: (1) Whether the action for annulment of sale and reconveyance was correctly dismissed on the ground of prescription; and (2) Whether the ejectment decision was valid despite the pending action questioning ownership.

RULING

The Supreme Court dismissed the petitions and affirmed the Court of Appeals. On the first issue, the action for annulment had clearly prescribed. The complaint itself alleged the sale occurred in 1957, but the suit was filed only in 1992, nearly 35 years later. Acquisitive prescription had set in, as private respondents’ open, continuous, and exclusive possession since 1957, which was in the concept of an owner, matured into ownership. The Court ruled that prescription could be determined from the allegations in the complaint, making a full trial unnecessary. The claim of an absolutely simulated contract, which does not prescribe, was unavailing as the facts alleged indicated a voidable contract due to alleged fraud, which prescribes in four years from its discovery.
On the second issue, the ejectment ruling was proper. The only issue in forcible entry cases is prior physical possession (possession de facto), not ownership. The MCTC validly found that private respondents, through their predecessors-in-interest, had prior possession since 1957, which was disturbed by the heirs’ entry in 1991. The summary nature of ejectment proceedings is designed for speedy relief, and the pendency of an action for annulment of title does not divest the inferior court of its jurisdiction over possession. A claim of ownership cannot override the specific issue of material possession in an ejectment suit.