G.R. No. 111676 March 4, 1999
SILVINA TORRES VDA. DE CRUZ, petitioner, vs. COURT OF APPEALS and PRISCILLA CRUZ-GATCHALIAN, respondents.

FACTS

Petitioner Silvina Torres Vda. de Cruz and private respondent Priscilla Cruz-Gatchalian are sisters-in-law. Private respondent is the registered owner of a 693 sq. m. lot in Bulacan, Bulacan, covered by OCT No. P-397-C. Petitioner, the widow of private respondent’s brother, resides with her children in a house built on this lot. After petitioner refused to comply with a demand to vacate, private respondent filed an ejectment case before the Municipal Trial Court (MTC). In her answer, petitioner denied private respondent’s ownership, asserting her own claim based on a tax declaration, and argued that the MTC lost jurisdiction because the core issue was ownership. She also cited a separate pending action for reconveyance she had filed before the Regional Trial Court (RTC).
The MTC ruled in favor of private respondent, ordering petitioner to vacate. This decision was affirmed by the RTC and subsequently by the Court of Appeals. The appellate court upheld the MTC’s jurisdiction, distinguishing material possession from legal ownership. Petitioner now contends before the Supreme Court that possession cannot be resolved without first settling the question of ownership, thereby ousting the MTC of jurisdiction.

ISSUE

Whether the Municipal Trial Court was divested of its jurisdiction over the ejectment case simply because the defendant raised the issue of ownership.

RULING

No. The Supreme Court affirmed the Court of Appeals’ decision, ruling that the MTC retained jurisdiction. The Court clarified that the jurisdiction of a court in ejectment cases (forcible entry or unlawful detainer) is determined by the allegations in the complaint. Private respondent’s complaint sufficiently alleged a cause of action for ejectment based on her ownership and petitioner’s withholding of possession after a demand to vacate. The fact that petitioner, in her answer, raised ownership as a defense and filed a separate action for reconveyance does not strip the MTC of its jurisdiction over the summary action for possession.
The legal logic is that ejectment cases precisely deal with the issue of physical or material possession (possession de facto), independent of the question of legal ownership (possession de jure). The exception—where the issue of possession is so intertwined with ownership that it cannot be decided separately—did not apply here. The Court cited its ruling in Dante v. Sison, which held that a pending action for annulment of title or reconveyance does not divest the MTC of jurisdiction. The purpose of ejectment proceedings is to provide a swift remedy for the restoration of possession, and allowing a collateral claim of ownership to derail this process would defeat that objective. The MTC was therefore correct in proceeding to adjudicate the issue of possession based on the evidence presented.