G.R. No. 100740. November 25, 1994.
SPOUSES ALFREDO AND MELINDA MUNAR, GLORIA PALISOC-RUGA, PACITA PALISOC, LYDIA PALISOC-ROSALES AND ILUMINADO PALISOC, petitioners, vs. COURT OF APPEALS AND SPOUSES RAMON AND REBECCA NIEVES, respondents.

FACTS

The Palisocs, as registered co-owners, executed a notarized Conditional Deed of Sale over a property in favor of the Nieveses. The Nieveses paid a portion of the price and were given a special power of attorney to collect rentals. The Nieveses later filed a successful complaint for specific performance to compel the execution of a final deed after paying the balance. Separately, the Nieveses filed an ejectment case against the Munars, tenants in the property, for non-payment of rent. The Munars defended by claiming the Nieveses’ authority to collect was revoked and that the sale was rescinded. The Palisocs sought to intervene in the ejectment case, asserting ownership, but the trial court denied intervention as a prohibited pleading under the Rule on Summary Procedure. The Munars later vacated, and the Palisocs themselves occupied the premises.

ISSUE

The core issue is whether the Metropolitan Trial Court correctly exercised jurisdiction over the ejectment case and ruled in favor of the Nieveses, despite the Palisocs’ claims of ownership and the pending specific performance case.

RULING

The Supreme Court affirmed the Court of Appeals’ decision upholding the ejectment ruling. The Court clarified that an ejectment case is a quieting process designed to determine only who has a better right of physical possession, not to resolve questions of ownership. The Nieveses’ prior possession was legally established. By virtue of the notarized Conditional Deed of Sale, execution of the public instrument was equivalent to the delivery of possession to the Nieveses in 1976. The Palisocs’ possession only began in 1986 when they occupied the premises after the Munars left. Therefore, the Nieveses had priority in time. The Palisocs’ allegations regarding the revocation of the power of attorney and the nullity of the sale due to non-payment were deemed irrelevant to the possessory issue in the ejectment suit; these were matters properly for resolution in the separate specific performance case. The Court noted that the specific performance case had already been resolved in favor of the Nieveses, rendering moot any consolidation argument. The exception where ownership is inseparably linked to possession did not apply, as prior possession was clearly established independently of the title dispute.