G.R. No. 180687 ; October 6, 2010
ESMERALDO C. ROMULLO, ET AL., Petitioners, vs. SAMAHANG MAGKAKAPITBAHAY NG BAYANIHAN COMPOUND HOMEOWNERS ASSOCIATION, INC., represented by its President, PAQUITO QUITALIG, Respondent.

FACTS

Respondent Samahang Magkakapitbahay ng Bayanihan Compound Homeowners Association, Inc., availed of a government loan under the Community Mortgage Program to purchase land for its housing project. The land was distributed to member-beneficiaries, including petitioners. Respondent alleged that petitioners refused to pay their monthly dues, amortizations, and other fees. Consequently, the association’s board passed resolutions expelling petitioners as members and disqualifying them as beneficiaries. Despite demands, petitioners refused to vacate their allocated lots, prompting respondent to file an ejectment case.
The Metropolitan Trial Court (MeTC) dismissed the complaint for lack of jurisdiction, citing a pending case filed by some petitioners before the Housing and Land Use Regulatory Board (HLURB) involving the same parties and issues. On appeal, the Regional Trial Court (RTC) reversed the MeTC, declaring respondent the lawful possessor and ordering petitioners to vacate and pay compensation. The Court of Appeals affirmed the RTC’s decision, prompting this petition.

ISSUE

Whether the MeTC had jurisdiction over the ejectment case despite the pendency of a related case before the HLURB.

RULING

Yes, the MeTC properly exercised jurisdiction. The Supreme Court affirmed the CA’s ruling, emphasizing the distinct nature of ejectment cases and cases before the HLURB. An ejectment suit, such as the one filed by respondent, is a summary proceeding designed to resolve the issue of physical possession (possession de facto) based on the parties’ right of possession at the time of filing. The core question is who has a better right to possess the property, independent of claims of ownership. The allegations in respondent’s complaint—that petitioners’ right to possess derived from their membership, which was terminated, and their subsequent refusal to vacate after demand—sufficiently constituted a cause of action for unlawful detainer within the MeTC’s jurisdiction.
The pendency of the HLURB case did not divest the MeTC of jurisdiction. The Court found no identity of causes of action between the two cases. The HLURB case involved intra-association matters, including the validity of the petitioners’ expulsion, calls for meetings, elections, and an accounting of funds. In contrast, the ejectment case solely concerned the right to physical possession of the lots. Since the rights asserted and the reliefs prayed for were different, the principle of litis pendentia did not apply. The MeTC could proceed independently to adjudicate the issue of possession.