GR 141493; (July, 2004) (Digest)
G.R. No. 141493 ; July 28, 2004
NATIONAL ONION GROWERS COOPERATIVE MARKETING ASSOCIATION, INC., petitioner, vs. ANTONIO LO and LAND BANK OF THE PHILIPPINES, respondents.
FACTS
Petitioner National Onion Growers Cooperative Marketing Association, Inc. (NOGCOMI) was a lessee of two lots owned by the Land Bank of the Philippines (LBP) under a lease contract expiring on December 31, 1995. LBP sold the lots to respondent Antonio Lo through public bidding in November 1995. NOGCOMI objected, claiming a preferential right to purchase as a cooperative under Presidential Decree No. 175, and filed an action for annulment of the sale in the Regional Trial Court (RTC) in December 1995.
Upon the lease’s expiration, Lo demanded that NOGCOMI vacate the premises. NOGCOMI refused, prompting Lo to file an ejectment complaint before the Metropolitan Trial Court (MTC) in February 1996. NOGCOMI moved to dismiss, arguing the MTC lost jurisdiction because the pending annulment case raised a question of ownership. The MTC ruled in favor of Lo, ordering NOGCOMI to vacate and pay compensation. The RTC and the Court of Appeals affirmed the MTC decision.
ISSUE
Whether the MTC loses jurisdiction over an ejectment case once the question of ownership is raised by the defendant.
RULING
No. The MTC retains jurisdiction. Jurisdiction over ejectment cases is determined by the allegations in the complaint, which in this case pertained to the expiration of the lease and the withholding of possession, constituting unlawful detainer. A defendant cannot divest the MTC of jurisdiction by merely raising the issue of ownership in its answer or by filing a separate action questioning title.
The sole issue in ejectment proceedings is physical or material possession (possession de facto), independent of any claims of ownership. When the question of ownership is intertwined with the issue of possession, the MTC is empowered under Section 16, Rule 70 of the Rules of Court to resolve the ownership issue provisionally, but only for the sole purpose of determining who has a better right to possession. Such a provisional determination does not constitute a final adjudication on ownership and does not bar or prejudice a separate action for title.
NOGCOMI, as a mere lessee whose lease had expired, had no legal right to retain possession. Its prior possession is irrelevant in unlawful detainer, which concerns the unjust withholding of possession after the right has ceased. The summary nature of ejectment is designed to provide a speedy remedy for possession, and allowing a separate annulment case to suspend it would defeat this purpose. The pendency of the annulment case did not oust the MTC of jurisdiction.