G.R. No. 147874 ; July 17, 2006
DOLORES GAYOSO, DANNY GAYOSO, ELIZABETH G. DONDRIANO, VICTORIANO GAYOSO, CHRISTOPHER GAYOSO, REMEDIOS GAYOSO and THE HEIRS OF VICTORIANO GAYOSO, petitioners, vs. TWENTY-TWO REALTY DEVELOPMENT CORPORATION, respondent.

FACTS

Respondent Twenty-Two Realty Development Corporation (TTRDC) filed an ejectment complaint for unlawful detainer against petitioners before the Metropolitan Trial Court (MeTC) of Mandaluyong City. TTRDC alleged it acquired ownership of the subject property from the heirs of Prospero Almeda, who originally purchased it from petitioners’ father, Victoriano Gayoso. Petitioners, who were allowed to stay as lessees, stopped paying rentals. Despite demand letters, they refused to vacate, prompting the suit.
In their Answer, petitioners contested the MeTC’s jurisdiction, asserting that the core issue involved ownership. They claimed the 1954 sale by their father was void for lack of spousal consent, rendering Almeda’s ownership defective and, consequently, TTRDC’s title invalid. The MeTC ruled for TTRDC, ordering petitioners to vacate and pay rentals and attorney’s fees. The Regional Trial Court and the Court of Appeals affirmed the MeTC’s decision.

ISSUE

Whether the MeTC had jurisdiction over the ejectment case despite petitioners raising the issue of ownership in their pleadings.

RULING

The Supreme Court affirmed the Court of Appeals, ruling that the MeTC validly exercised jurisdiction. The legal logic is anchored on the explicit provisions of law governing inferior courts. Under Section 33(2) of Batas Pambansa Blg. 129, as amended, Metropolitan Trial Courts retain exclusive original jurisdiction over unlawful detainer cases even when the defendant raises ownership as a defense. The rule expressly provides that the issue of ownership may be resolved provisionally, but only for the singular purpose of adjudicating the question of possession.
This principle is reinforced by Section 18, Rule 70 of the Rules of Court, which states that a judgment in an ejectment case is conclusive only on possession and does not bind title or affect ownership. Jurisprudence consistently holds that inferior courts are competent to resolve questions of ownership if necessary to decide possession, without such determination constituting a final adjudication on title. The petitioners’ defense challenging the validity of the sale and TTRDC’s title did not divest the MeTC of jurisdiction. The court could provisionally examine the ownership claim to determine who had a better right of possession, which it did based on TTRDC’s registered title and the lease arrangement. Therefore, the MeTC correctly assumed jurisdiction and decided the ejectment case.