G.R. No. 154203; July 8, 2003
REY CARLO A. RIVERA and GLADYS ABAGA RIVERA, petitioners, vs. VIRGILIO RIVERA, respondent.

FACTS

The property in dispute is a lot with a duplex house in Pasig City, originally owned by spouses Remigio Rivera, Sr. and Consuelo Rivera. In 1974, petitioners, grandchildren of the spouses, began occupying one unit of the house by tolerance of their grandparents. In 1992, after Remigio Sr.’s death, all heirs executed an extrajudicial settlement waiving their rights to the property in favor of their mother, Consuelo. In 1999, Consuelo, while residing abroad, sold the property to her son, respondent Virgilio Rivera. Respondent, now the registered owner, demanded petitioners sign a lease contract. Upon their refusal, he filed an ejectment case for unlawful detainer.
Petitioners contested the ejectment, arguing the deed of sale was fictitious and that they possessed the property as co-owners, having resided there since 1974. They asserted the MeTC had no jurisdiction as the core issue was ownership, not mere possession. The MeTC ruled for respondent, ordering petitioners to vacate and pay rentals. The RTC reversed, holding petitioners were co-owners. The Court of Appeals reinstated the MeTC decision.

ISSUE

Whether the Metropolitan Trial Court had jurisdiction over the ejectment case despite petitioners’ claim of ownership.

RULING

Yes, the MeTC properly exercised jurisdiction. The Supreme Court affirmed the Court of Appeals. In ejectment cases, the municipal court retains jurisdiction even if the defendant raises the issue of ownership, provided the complaint sufficiently alleges prior physical possession by the plaintiff and subsequent deprivation by the defendant. The underlying policy is to prevent defendants from defeating the summary nature of ejectment suits by merely asserting ownership.
Here, respondent’s complaint adequately alleged that petitioners’ possession was by mere tolerance, which ended upon their refusal to sign a lease contract after respondent acquired title. The determination of ownership by the MeTC was provisional, made solely to resolve the issue of possession. This adjudication does not bar a separate action for the final settlement of title. Petitioners’ claims regarding the validity of the sale and their alleged co-ownership are substantive issues that must be ventilated in an appropriate proceeding, such as an action for reconveyance or annulment of title, not in the summary action for ejectment. Consequently, as the registered owner, respondent was entitled to possession, and the order for petitioners to vacate was proper.