GR 158166; (January, 2005) (Digest)
G.R. No. 158166 ; January 21, 2005
Minerva Umpoc, Atty. Ildebrando Viernesto and Ethel Manaloto, petitioners, vs. Mildred Mercado as Administratrix of the Estate of the late Dr. Jesusa Barrios, respondent.
FACTS
Respondent Mildred Mercado was appointed administratrix of the estate of the late Dr. Jesusa Barrios. In her capacity, she sought to take possession of a four-unit apartment building registered in the decedent’s name. Petitioners Minerva Umpoc, Atty. Ildebrando Viernesto, and Ethel Manaloto were occupants of the units. Respondent sent demand letters for them to vacate and pay rentals. Petitioners refused, claiming the property was no longer part of the estate. They asserted ownership by virtue of an unregistered Deed of Sale dated March 30, 1987, allegedly executed by Dr. Barrios in favor of certain individuals, including petitioner Viernesto’s father.
Respondent filed separate unlawful detainer cases against each petitioner before the Metropolitan Trial Court (MeTC). In their answers, petitioners uniformly anchored their right to possess the units on the 1987 Deed of Sale, claiming they derived their possession from the alleged vendees. Simultaneously, respondent filed a separate action for the annulment of the same Deed of Sale. The MeTC ruled in favor of the respondent, a decision affirmed by the Regional Trial Court (RTC) and the Court of Appeals (CA).
ISSUE
Whether the MeTC had jurisdiction over the unlawful detainer cases despite the petitioners’ assertion of ownership based on an unregistered deed of sale.
RULING
Yes, the MeTC retained jurisdiction. The Supreme Court held that an ejectment suit is designed to resolve the issue of physical possession (possession de facto) independently of claims of ownership. Jurisdiction is conferred by the allegations in the complaint. Respondent’s complaint sufficiently alleged a cause of action for unlawful detainer by stating that petitioners’ right to occupy the premises, whether by lease or tolerance, was terminated upon the owner’s death and subsequent demand to vacate.
The petitioners’ defense of ownership, premised on the 1987 Deed of Sale, did not divest the MeTC of jurisdiction. The court explained that the mere assertion of ownership by a defendant does not automatically oust the inferior court of its authority over the ejectment case. The issue of ownership need only be resolved preliminarily to settle the question of possession. Here, the alleged deed was unregistered and its validity was directly challenged in a separate annulment case. Thus, title remained with the registered owner, the decedent, whose estate was represented by the respondent-administratrix. The administratrix, by law, has the right to possession of estate properties for purposes of administration. Therefore, the MeTC correctly adjudged possession in favor of the estate.