G.R. No. 125375 ; June 17, 2004
Spouses Elpidio Apostol and Amelia Apostol, petitioners, vs. Court of Appeals and Spouses Emmanuel Chua and Edna L. Chua, respondents.

FACTS

The respondents, Spouses Chua, purchased a parcel of land from Spouses Pascua. The petitioners, Spouses Apostol, were occupying the property and verbally assured the Chuas they would vacate within ten days from the sale’s execution. A Deed of Absolute Sale was executed on June 7, 1993, and TCT No. 87610 was issued to the Chuas on June 8, 1993. Despite demands, the Apostols refused to leave. The Chuas filed an unlawful detainer case in the MeTC. The Apostols contested, claiming prior purchase and possession since 1973, and filed a separate RTC case for annulment of the sale and title, and for reconveyance.
The MeTC ruled for the Chuas, ordering the Apostols to vacate. The RTC, on appeal, reversed, dismissing the ejectment case, holding that the issue of possession was intertwined with ownership due to the Apostols’ claim of a prior sale. The Court of Appeals then reinstated the MeTC decision, ruling that a Torrens title holder is entitled to possession and that the title’s validity cannot be collaterally attacked in an ejectment suit.

ISSUE

Whether the complaint for unlawful detainer should be dismissed on the ground that the issue of possession is intertwined with the issue of ownership, which is pending in a separate annulment case.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is clear: a Torrens certificate of title is conclusive evidence of ownership, and the registered owner is entitled to possession. The action for unlawful detainer is summary and determines only the issue of physical possession based on legal tolerance or contract, not ownership. The Apostols’ claim that the Chuas’ title is void constitutes a collateral attack, which is prohibited under Section 48 of P.D. No. 1529. A certificate of title can only be challenged in a direct proceeding expressly instituted for that purpose.
The pendency of the Apostols’ separate action for annulment and reconveyance in the RTC does not divest the MeTC of its jurisdiction over the ejectment case. The issue of who has a better right of ownership—including allegations of being buyers in bad faith or the validity of the sale—is beyond the scope of unlawful detainer and is precisely the subject of the pending annulment case. Therefore, the lower courts correctly prioritized the Chuas’ right to possession as registered owners, without pre-judging the ultimate issue of ownership to be resolved in the direct action.