GR 176282; (August, 2008) (Digest)
G.R. No. 176282 ; August 22, 2008
VICTORIA FERNANDO, petitioner, vs. SPS. REGINALDO LIM and ASUNCION LIM, respondents.
FACTS
Lim Kieh Tong and Sons, Inc. (LKTSI) owned a parcel of land in Manila, including a unit (Unit 1682) occupied by petitioner Victoria Fernando under a month-to-month lease. Upon its dissolution, LKTSI executed a Deed of Assignment transferring the property to its stockholder, respondent Reginaldo Lim, who, with his spouse, secured new titles. The respondents, as new owners, informed Fernando by letter that her lease would not be renewed and demanded she vacate the premises. Upon her refusal, they filed an ejectment complaint.
In her defense, Fernando argued the MeTC lacked jurisdiction because the case involved an issue of title. She claimed the Deed of Assignment violated Section 6 of P.D. No. 1517 (Urban Land Reform Law), which grants legitimate tenants of ten years a right of first refusal and protection from dispossession. She also contended she had built improvements on the unit, raising a question of ownership. The MeTC ruled for the Lims, ordering Fernando to vacate and pay rentals and attorney’s fees. The RTC and the Court of Appeals affirmed the decision.
ISSUE
Whether the Metropolitan Trial Court had jurisdiction over the ejectment case despite the petitioner’s invocation of P.D. No. 1517 and her claim raising an issue of ownership.
RULING
Yes, the MeTC properly exercised jurisdiction. The Court held that an ejectment case is fundamentally 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, which in this case pleaded a simple case of unlawful detainer based on the termination of a month-to-month lease and the owner’s demand to vacate.
The petitioner’s invocation of P.D. No. 1517 and her claim of having built the unit did not divest the MeTC of jurisdiction. Under the Rules of Court, when a defendant in an ejectment case raises the question of ownership, the court may resolve it but only for the purpose of determining the issue of possession. The alleged violation of P.D. No. 1517 pertains to the validity of the transfer of ownership, which is a separate issue from the right of possession upon which the ejectment is based. The respondents’ title, registered under the Torrens system, served as sufficient basis for their right to institute the ejectment suit. The existence of a title dispute does not oust the MeTC’s jurisdiction; it merely requires the court to adjudicate possession, which it did correctly by ordering Fernando to vacate.