GR 152745; (March, 2004) (Digest)
G.R. No. 152745; March 17, 2004
DIANA JEANNE LOPEZ, petitioner, vs. SPOUSES EDILBERTO and EVELINE POZON and COURT OF APPEALS, respondents.
FACTS
Respondents Spouses Pozon entered into an Agreement to Purchase and to Sell with Tradex Development Corporation for a house and lot in Dasmarinas Village. Tradex unilaterally rescinded the contract and sold the property to another entity. The Pozons filed an action for specific performance. The RTC ruled in their favor, a decision ultimately affirmed by the Supreme Court. After Tradex failed to deliver possession, the RTC divested Tradex of its title and directed the Register of Deeds to cancel Tradex’s TCT and issue a new one in the Pozons’ names.
To gain physical possession, the Pozons filed an ejectment case against the occupant, petitioner Diana Jeanne Lopez. Lopez claimed she was the real owner, having allegedly purchased the property from Enrique Zobel, and argued the MeTC had no jurisdiction as the action involved a question of ownership. She also contended the judgment against Tradex was not binding on her and that she had a pending quieting of title case.
ISSUE
Whether the Metropolitan Trial Court correctly assumed jurisdiction over the ejectment case and ruled in favor of the Pozons.
RULING
Yes. The Supreme Court denied Lopez’s petition and affirmed the lower courts’ rulings. In an ejectment case, the sole issue is physical or material possession, not ownership. Jurisdiction is determined by the allegations in the complaint, which here pertained to the deprivation of possession. Lopez’s assertion of ownership does not oust the MeTC of its jurisdiction; such a defense does not alter the possessory nature of the action.
The Pozons’ right to possession is firmly anchored on their Transfer Certificate of Title (TCT), which is conclusive evidence of ownership under the land registration laws. A certificate of title cannot be collaterally attacked in an ejectment proceeding; it can only be challenged in a direct proceeding, such as the quieting of title case Lopez had initiated separately. The Court emphasized it is not a trier of facts and cannot, in this petition, evaluate the factual merits of Lopez’s claim of ownership, which must be ventilated in the proper forum. The Pozons, as registered owners under a valid TCT, have a superior right to possession that is enforceable in an ejectment action.