GR 126638; (February, 2002) (Digest)
G.R. No. 126638 ; February 6, 2002
ROSANNA B. BARBA, petitioner, vs. COURT OF APPEALS, TEODORA GARCIA, TESS GARCIA, SEVILLA GARCIA, RODRIGO SALAZAR, and ABRAHAM VELASQUEZ, respondents.
FACTS
Petitioner Rosanna Barba filed an ejectment complaint before the Municipal Circuit Trial Court (MCTC) against private respondents. Barba alleged she became the owner of the subject property after foreclosing a mortgage executed by respondent Teodora Garcia. Upon Teodora’s failure to redeem, a new Transfer Certificate of Title (TCT) was issued in Barba’s name. After making a demand to vacate, which was refused, Barba initiated the ejectment case.
In their answer, respondents (except Teodora) claimed Sevilla Garcia was the true owner, having purchased the property in 1975. They alleged Teodora, through a falsified deed of sale, fraudulently obtained title in her name, which was later mortgaged to Barba. Sevilla had filed a criminal case for falsification and a separate civil action for annulment of deed and reconveyance. The MCTC ruled in favor of Barba, but the Regional Trial Court (RTC) reversed, dismissing the case for lack of jurisdiction due to the complaint’s failure to allege prior possession.
ISSUE
Whether the Court of Appeals erred in affirming the dismissal of the ejectment case on the ground that a genuine issue of ownership, allegedly inextricably linked to possession, deprived the inferior court of jurisdiction.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the MCTC decision. The legal logic is anchored on the nature and limited jurisdiction of ejectment actions. An ejectment suit is fundamentally a quieting process designed to restore physical possession (possession de facto), not to resolve title (possession de jure). Jurisdiction is conferred by the allegations in the complaint concerning the nature of the plaintiff’s possession and the manner of the defendant’s deprivation thereof.
The Court held that the pendency of an action for annulment of title or reconveyance does not divest the MCTC of its jurisdiction over the ejectment case. The summary nature of ejectment cannot be circumvented by merely raising a claim of ownership. The issue of ownership need only be resolved preliminarily for the sole purpose of determining the issue of possession. In this case, Barba, as the registered owner under a TCT, had a better right of possession that could be enforced in an ejectment proceeding, irrespective of the collateral attack on her title by the respondents. The Court emphasized that a Torrens title is evidence of an indefeasible and incontrovertible right of ownership, which includes the right to possess. Therefore, the inferior court correctly exercised its jurisdiction, and the ejectment case should proceed independently of the action for reconveyance.