G.R. No. 175561; October 20, 2010
SPOUSES IDA aka “MILAGROS” NIEVES BELTRAN and JOSE BELTRAN, Petitioners, vs. ANITA R. NIEVES, represented by NELIA G. MORAN, Respondent.

FACTS

Respondent Anita R. Nieves is the registered owner of a parcel of land and a house in Camalig, Albay, as evidenced by Transfer Certificate of Title No. T-10963. Petitioners, spouses Milagros Nieves Beltran (Nieves’s niece) and Jose Beltran, have been occupying the property. Nieves filed a complaint for ejectment, alleging she merely tolerated the occupation by her relatives, including Milagros’s father, Gaston, and that despite demands, the spouses refused to vacate.
The spouses Beltran claimed their possession was in the concept of owners as intestate heirs of Gaston. They asserted that Nieves had sold the property to Gaston via an unregistered deed of sale dated December 1964. The Municipal Circuit Trial Court (MCTC) dismissed the ejectment complaint, provisionally ruling that Gaston owned the property by virtue of the unregistered deed. The Regional Trial Court (RTC) affirmed, holding that the MCTC had no jurisdiction to determine just title and that the complaint failed to allege the specific date possession became unlawful.

ISSUE

Whether the spouses Beltran have a better right of possession over the subject property, thereby warranting the dismissal of the ejectment complaint filed by the registered owner, Anita Nieves.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision ordering the spouses Beltran to vacate. The legal logic is anchored on the nature of ejectment proceedings and the indefeasibility of a Torrens title. An ejectment case is a summary action designed to resolve the issue of physical possession (possession de facto) independently of claims of ownership. The sole question is who has a better right to possess.
Here, Nieves, as the registered owner under a Torrens certificate of title, has a superior right of possession that cannot be defeated by the petitioners’ claim based on an unregistered and disputed deed of sale. The Court emphasized that a certificate of title is not subject to collateral attack in an ejectment suit. Any challenge to the validity of Nieves’s title must be made in a direct action expressly instituted for that purpose. The petitioners’ possession, initially by tolerance of the owner, became unlawful upon her demand to vacate. Their continued refusal to leave despite demand made the ejectment suit proper. Prior physical possession, argued by the petitioners, is immaterial as this is not a forcible entry case but one of unlawful detainer arising from the termination of the owner’s tolerance.