GR 132657; (January, 2000) (Digest)
G.R. No. 132657 January 19, 2000
SPOUSES WILLIAM and JANE JEAN DIU, petitioners, vs. DOMINADOR IBAJAN, DEMETRIA IBAJAN, NELSON C. SY, VICENTE REALINO II and ROMEO R. ALVERO, respondents.
FACTS
The spouses Carmelito and Finna Ibajan, joined by Dominador and Demetria Ibajan, filed an action for annulment of deeds of sale involving a parcel of land and a building against William Diu (Civil Case No. B-0952). They alleged that Diu procured a deed of absolute sale over the lot through misrepresentation and a forged deed for the building. Shortly after, the spouses William and Jane Jean Diu filed a forcible entry complaint (Civil Case No. 460) before the Municipal Trial Court (MTC) against the Ibajans and others, alleging that the defendants unlawfully entered the same property, ejected their employees, and took possession. The MTC ruled in favor of the Diu spouses, ordering the defendants to vacate and pay damages.
ISSUE
Whether the Regional Trial Court (RTC), acting as an appellate court in the forcible entry case, correctly dismissed the appeal on the ground that it lacked jurisdiction due to the pendency of an annulment case raising issues of ownership.
RULING
No. The RTC erred in dismissing the forcible entry case on appeal. The Supreme Court clarified that an ejectment suit, such as forcible entry, is primarily concerned with the issue of physical or material possession (possession de facto) independent of any claim of ownership. The pendency of an action for annulment of title, which inherently involves ownership, does not divest the MTC of its jurisdiction over the ejectment case. The two actions can proceed independently and simultaneously. The rule is that the MTC retains jurisdiction over ejectment cases even if the defendant raises the question of ownership; the court may resolve such issue but only to determine the issue of possession. Furthermore, the RTC, on appeal, is confined to reviewing the records of the proceedings from the court of origin and cannot conduct a trial de novo or dismiss the case based on a perceived conflict with a separate action for annulment. The Court also found no forum shopping, as the two cases involved different causes of action and did not constitute repetitive suits for the same relief. The order of dismissal was reversed, and the RTC was directed to resolve the appeal on its merits based on the MTC record.