G.R. No. L-4770 June 30, 1953
Baltazar Raymundo, petitioner, vs. Braulio Santos, respondent.

FACTS

The case originated as an unlawful detainer action in the justice of the peace court of Pasig, Rizal, filed by respondent Braulio Santos against petitioner Baltazar Raymundo. Santos alleged he was the vendee of a parcel of land with a bakery building and that Raymundo unlawfully withheld possession. The justice of the peace court ruled for Santos. On appeal, the Court of First Instance of Rizal, presided by Judge Ambrosio Santos, dismissed the case, holding that the action necessarily involved the question of ownership over the property, which was beyond the jurisdiction of the inferior court.
The antecedent facts, as found, are: Spouses Baltazar Raymundo and Agapita San Juan were the registered owners of the property (covered by Original Certificate of Title No. 3199). They mortgaged it to Macondray & Co., Inc. to secure a P3,000 debt. On August 29, 1931, the spouses executed a deed (Exhibit B) in favor of Felisa A. Afable, who assumed the mortgage obligation. Raymundo claimed this was merely an assignment of the mortgage credit. However, the deed was an absolute deed of sale, and as a result, Transfer Certificate of Title No. 20666 was issued to Afable on November 21, 1931. The Raymundos remained in possession, paying Afable P30 monthly. In October 1945, Afable sold the property to Braulio Santos for P22,000, and Transfer Certificate of Title No. 20666 was cancelled, and a new title issued in Santos’s name. Santos then sought to take possession, leading to the detainer suit.
Raymundo defended by claiming Afable fraudulently obtained a deed of absolute sale instead of a mere mortgage assignment. The Court of First Instance found the resolution of the possession issue depended on determining the validity of the title, which involved questions of ownership beyond the summary jurisdiction of an unlawful detainer case. The Court of Appeals reversed, ordering Raymundo to vacate and pay for use and occupation, holding that the issuance of a certificate of title to Santos rendered the ownership question immaterial for purposes of the detainer action.

ISSUE

Whether the justice of the peace court (and the Court of First Instance on appeal) had jurisdiction over the subject matter of the action, given that the issue of possession was inextricably linked to the question of ownership or title to the property.

RULING

The Supreme Court REVERSED the decision of the Court of Appeals and DISMISSED the action. The Court held that the justice of the peace court lacked jurisdiction because the action for unlawful detainer necessarily involved the determination of ownership or title to the property. The Court found that the defendant’s claim of possession in the concept of owner and his challenge to the validity of the plaintiff’s title, based on alleged fraud in the source title, presented substantial questions that exceeded the scope of a summary possessory action. The resolution of the possession issue depended inexorably on first resolving the question of ownership. The case was substantially similar to Torres vs. Peña, where it was ruled that when the determination of the possessory question depends on the determination of the title, the inferior court loses jurisdiction. The fact that a certificate of title had been issued in the plaintiff’s name did not remove the jurisdictional defect, as that title was itself contested on grounds of fraud. The Court emphasized that the defendant had consistently raised the jurisdictional issue from the justice of the peace court through the Court of First Instance.