GR 155478; (April, 2005) (Digest)
G.R. No. 155478 . April 29, 2005
SPOUSES GUILLERMO and ANDYLYNN HIZO, Petitioners, vs. COURT OF APPEALS and SAMMIE BACORRO, represented by Attorney-in-Fact BENILDA BACORRO, Respondents.
FACTS
Maria Tabayoyong owned a residential lot in Quezon City. In 1966, she permitted her sister to build a house on a portion of the property, which was later occupied by the spouses Guillermo and Andylynn Hizo. Tabayoyong later sold the lot to her nephew, Sammie Bacorro. Bacorro demanded that the Hizo spouses vacate the premises and, upon their refusal, filed an unlawful detainer case. The Metropolitan Trial Court (MTC) ruled in Bacorro’s favor, ordering the spouses to vacate and pay rentals.
During the appeal, a relocation survey revealed that only one-third of the Hizo spouses’ house was situated on Bacorro’s lot (Lot 6), occupying 18 square meters. The remaining two-thirds was built on an adjacent property, Lot 13, identified as a public alley. The Regional Trial Court (RTC), on appeal, affirmed the MTC decision but modified the order to include the demolition of the entire house, including the portion on Lot 13. The Court of Appeals upheld this modified demolition order.
ISSUE
Whether the courts, in an unlawful detainer case, can order the demolition of portions of a structure located outside the property subject of the ejectment suit.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the MTC decision as affirmed by the RTC but without the modification for full demolition. The legal logic is grounded in the limited jurisdiction of courts in ejectment cases. An action for unlawful detainer is a summary proceeding designed to provide a speedy remedy for the recovery of physical possession of a specific property. The court’s jurisdiction is confined solely to the property subject of the complaint.
Here, the evidence established that only 18 square meters of the Hizo spouses’ house encroached on Bacorro’s Lot 6. The two-thirds portion stood on Lot 13, a separate parcel. Consequently, the MTC and the RTC on appeal only had the authority to order the eviction of the petitioners from Bacorro’s property—the 18-square-meter portion. They lacked jurisdiction to order the demolition of the house section situated on Lot 13, which was beyond the property involved in the unlawful detainer suit. The Court emphasized that if Bacorro believed the structure on Lot 13 constituted a nuisance or that the spouses were improperly using his property for access, his proper remedy was a separate action, not an expansion of the ejectment case. The judgment of a court acting beyond its statutory authority is void for lack of jurisdiction over the subject matter.