G.R. No. L-10769; March 23, 1916

FACTS:
Raymundo Melliza filed an action to recover possession of a parcel of real estate and to claim damages for its unlawful detention. The defendants, F. W. Towle and Enrique Mueller, opposed the claim. During the trial, the court admitted in evidence Exhibit 2, a Torrens system certificate of title issued to Towle for the land in question. The trial court ruled in favor of the defendants and dismissed the complaint. Melliza appealed, assigning as errors the admission of Exhibit 2 and the dismissal of his complaint.

ISSUE:
1. Whether the trial court erred in admitting evidence of ownership (the Torrens title) in an action for possession.
2. Whether the trial court erred in dismissing the complaint based on its factual findings regarding possession.

RULING:
1. On the admissibility of Exhibit 2: The Supreme Court held that the trial court did not err in admitting the Torrens certificate of title. The appellant argued that in an action for possession, evidence of ownership is inadmissible. The Court clarified that the action filed was not one for unlawful entry and detainer under Section 80 of the Code of Civil Procedure, as the complaint did not allege the specific grounds required for such an action (e.g., possession obtained by force, intimidation, strategy, stealth, or unlawful withholding after contract expiration). Instead, the complaint alleged ownership and the consequent right to possession, making evidence of ownership relevant and admissible.