G.R. No. 167554 ; February 26, 2008
Romeo Asis, Oscar Asis and Eduardo Asis, petitioners, vs. Consuelo Asis Vda. De Guevarra, respondent.

FACTS

Respondent Consuelo Asis Vda. De Guevarra filed separate ejectment complaints against her brothers, petitioners Romeo, Oscar, and Eduardo Asis, before the Metropolitan Trial Court (MeTC) of Manila. She claimed sole ownership of three apartment units built on a lot co-owned by all siblings, alleging she financed their construction. Respondent asserted petitioners were her lessees who paid monthly rentals but subsequently stopped without justification. Petitioners, in their Answers, claimed co-ownership of both the lot and apartments by inheritance, denying any landlord-tenant relationship. They contended any payments made were for maintenance or family support, not rent.
The MeTC consolidated the cases and ruled for respondent, ordering petitioners to vacate and pay accrued rentals and compensation for use. The MeTC found respondent’s evidence of ownership (SSS loan records and tax declarations) and lease (receipts) more credible than petitioners’ bare allegations of co-ownership. The Regional Trial Court (RTC) affirmed the MeTC decision. However, the Court of Appeals (CA) reversed, dismissing the ejectment cases for lack of jurisdiction. The CA held the core issue was ownership, not possession, thus falling outside the MeTC’s limited jurisdiction over ejectment suits.

ISSUE

Whether the MeTC had jurisdiction over the ejectment cases despite the intertwined issue of ownership.

RULING

Yes, the MeTC retained jurisdiction. The Supreme Court clarified that an ejectment action is fundamentally designed to restore physical possession (possession de facto). Jurisdiction lies with the inferior court provided the plaintiff’s main objective is to recover possession. The necessity to resolve ownership does not automatically divest the MeTC of jurisdiction; it may provisionally rule on ownership only to determine the superior right of possession. Such a determination is merely incidental and does not constitute a final, binding adjudication on title.
In this case, respondent’s primary and ultimate relief sought was the restoration of possession of the apartments, premised on a lessor-lessee relationship. The existence of a lease inherently involves a recognition of the lessor’s better right to possess. To resolve who had the right to possess, the MeTC had to make a preliminary assessment of who owned the improvements. Its finding that respondent owned the apartments was precisely for this limited purpose. Petitioners failed to demonstrate that ownership was the principal issue raised in the pleadings to the exclusion of possession. Consequently, the CA erred in dismissing the cases for lack of jurisdiction. The Supreme Court reinstated the MeTC decision, noting it would not bar a separate action for conclusive title determination.