GR 147776; (July, 2007) (Digest)
G.R. No. 147776; July 10, 2007
SPS. GUILLERMO MALISON and AMELITA MALISON, Petitioners, vs. HON. COURT OF APPEALS, SPS. MELCHOR MARANAN, JR. and VIRGINIA MARANAN, Respondents.
FACTS
Respondents Spouses Maranan filed an ejectment complaint against petitioners Spouses Malison before the Metropolitan Trial Court (MeTC). The Maranans alleged they are the registered owners of a property in Quezon City, having purchased it in 1991 from Belen Eser-Pascual through her attorney-in-fact, Luz Eser-Tabing. They claimed the Malisons’ possession was by mere tolerance, which was withdrawn through a demand to vacate in 1997. The Malisons presented a contrary narrative, asserting petitioner Amelita Malison and her siblings were the true beneficial owners. They claimed the title was merely in Belen’s name for loan purposes and that Belen had authorized Luz to sell the property specifically to the Malisons for ₱400,000.00. They argued the sale to the Maranans was spurious and in excess of Luz’s authority.
ISSUE
Whether the MeTC had jurisdiction over the ejectment case despite the petitioners’ challenge to the respondents’ title.
RULING
Yes, the MeTC validly exercised jurisdiction. The Court emphasized the limited scope of ejectment cases, which are designed to provide a speedy remedy for the physical possession of property. Jurisdiction is conferred by the allegations in the complaint concerning the nature of the possession and the manner of its deprivation. Here, the respondents’ complaint sufficiently alleged possession by tolerance, which became unlawful upon demand. The petitioners’ defense, which essentially challenged the validity of the respondents’ title and the deed of sale, raised an issue of ownership. However, such a defense does not divest the MeTC of its jurisdiction over the possessory action. The Court ruled that a claim of ownership does not automatically oust the inferior court of jurisdiction; it may still resolve the issue of possession independently, provided it does not make a definitive pronouncement on title. The respondents’ Torrens title enjoys the presumption of validity and cannot be collaterally attacked in an ejectment suit. The legality of the sale and the scope of the agent’s authority are matters properly adjudicable in a direct action for annulment of title or reconveyance, not in a summary proceeding for ejectment. The MeTC and the higher courts correctly found that the respondents, as registered owners, had a better right to possession, and the petitioners’ possession, initially lawful by tolerance, became illegal upon the valid demand to vacate.