G.R. No. 147812. April 6, 2005
LEONARDO R. OCAMPO, Petitioner, vs. LEONORA TIRONA, Respondent.
FACTS
Petitioner Leonardo Ocampo filed an unlawful detainer complaint against respondent Leonora Tirona, a lessee occupying a portion of his land in Pasay City. Ocampo alleged he purchased the property from an heir of the registered owner and, despite the title not yet being in his name, he had taken over its management. He notified Tirona of the change in ownership and demanded payment of rentals. Tirona initially paid but later stopped, invoking a right of first refusal under Presidential Decree No. 1517, as the area was declared a priority development zone. After Tirona failed to comply with subsequent demands to pay and vacate, Ocampo initiated the ejectment case.
In her defense, Tirona claimed Ocampo was not the true owner, asserting that the land was part of an older title held by another individual, Doña Lourdes Rodriguez Yaneza, from whom she derived her right of possession. She also reiterated her claim under P.D. No. 1517. The Metropolitan Trial Court (MTC) ruled in favor of Ocampo, ordering Tirona to vacate and pay arrears. The Regional Trial Court (RTC) affirmed this decision. However, the Court of Appeals (CA) reversed, dismissing the complaint for lack of jurisdiction, reasoning that the core issue of ownership had been put in serious doubt, thereby removing the case from the summary nature of an ejectment suit.
ISSUE
Whether the Court of Appeals erred in dismissing the unlawful detainer complaint on the ground that the MTC lost jurisdiction due to the raised issue of ownership.
RULING
Yes, the Supreme Court reversed the Court of Appeals and reinstated the MTC decision. The Court clarified that an ejectment suit, whether for unlawful detainer or forcible entry, is a quieting process designed to restore physical possession (possession de facto), not to resolve questions of legal ownership (possession de jure). Jurisdiction in such cases is conferred by the allegations in the complaint concerning the nature of the defendant’s entry and the withholding of possession.
The Court held that the MTC retains jurisdiction over an ejectment case even if the defendant raises the question of ownership, provided the issue of possession can be resolved independently. The defense of ownership does not automatically divest the inferior court of jurisdiction. In this case, Tirona’s claim of a better title from another source did not negate the factual basis of Ocampo’s complaint: that she was initially a lessee who later refused to pay rent and vacate upon demand. The MTC correctly proceeded to determine who had the better right of possession based on the evidence presented, which overwhelmingly favored Ocampo. The CA therefore erred in dismissing the case for lack of jurisdiction.