G.R. No. 165831; February 23, 2007
SPS. COL. PEDRO L. LUMBRES and REBECCA ROARING, Petitioners, vs. SPS. PEDRO B. TABLADA, JR. and ZENAIDA N. TABLADA, Respondents.

FACTS

This case involves a double sale of a subdivision lot. Respondent spouses Tablada entered into a Contract to Sell with Spring Homes Subdivision Company, Inc. on January 9, 1995. They made substantial payments totaling ₱179,500, and on January 16, 1996, Spring Homes executed a Deed of Absolute Sale in their favor. The respondents constructed a house on the lot, secured a Certificate of Occupancy, and paid real property taxes. However, a balance of ₱230,000 from a contemplated Pag-IBIG loan remained unpaid.
Petitioner spouses Lumbres, in a separate civil case against Spring Homes, entered into a Compromise Agreement approved by the RTC on October 28, 1999, wherein Spring Homes assigned various properties, including the subject lot, to them. Subsequently, Spring Homes executed another Deed of Absolute Sale over the same lot in favor of the petitioners on December 22, 2000, for ₱157,500. A new title was issued to the petitioners, who then filed an ejectment case against the respondents.

ISSUE

The core issue is who between the two sets of purchasers has a better right to possess the property, thereby determining the propriety of the ejectment action.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision dismissing the ejectment complaint. The legal logic rests on the principle of prior possession and the nature of ejectment proceedings. The respondents, as prior possessors in good faith, have a superior right to remain in physical possession. Ejectment, being a possessory action, primarily concerns prior physical possession, not title. The Court found the respondents’ possession lawful and rooted in their 1996 Deed of Absolute Sale, which vested ownership upon full payment of the agreed price, notwithstanding the unpaid loan balance which was a separate contractual matter.
Crucially, by the time Spring Homes executed the second deed in favor of the petitioners in 2000, it had already divested itself of ownership through the first sale to the respondents. Therefore, the petitioners acquired no right to dispossess the respondents through a summary ejectment suit. The proper recourse for the petitioners, who claim a better title via the later sale and compromise agreement, is a plenary action for reconveyance or to assert ownership, not an action for ejectment. The respondents’ prior and continuous possession bars their summary ejectment.