G.R. No. 208284. April 23, 2018.
THE IGLESIA DE JESUCRISTO JERUSALEM NUEVA OF MANILA, PHILIPPINES, INC., represented by its President, FRANCISCO GALVEZ, Petitioner, vs. LOIDA DELA CRUZ using the name CHURCH OF JESUS CHRIST, “NEW JERUSALEM” and all persons claiming rights under her, Respondents.

FACTS

Petitioner Iglesia De Jesucristo Jerusalem Nueva of Manila, Philippines, Inc., represented by its President Francisco Galvez, filed a Complaint for unlawful detainer against respondent Loida Dela Cruz before the Metropolitan Trial Court (MeTC) of Malabon City. Petitioner alleged it is the owner of parcels of land covered by Original Certificate of Title (OCT) No. 35266 and Tax Declaration No. 06223, with a chapel built on the lot by its founder Rosendo Gatchalian in 1940. Petitioner claimed that respondent, a former member, occupied the chapel and lot by mere tolerance. After Rosendo’s death, members became disorganized, and respondent, without petitioner’s knowledge, formed the “Church of Jesus Christ, New Jerusalem” in 1998 and used it to claim rights over the property. A demand to vacate was sent on February 12, 2007, but respondent refused.
Respondent Dela Cruz, representing herself as an officer of “Obispe Representante at Pastor General ng Iglesia ni Jesu Kristo ‘Bagong Jerusalem’ Inc.,” denied petitioner’s claims. She asserted that the true owner of the property is the religious organization known under three nomenclatures: “Church of Jesus Christ New Jerusalem,” “Iglesia ni Jesu-Kristo Bagong Jerusalem,” and “Iglesia De Jesucristo Jerusalem Nueva,” which was registered as a corporation sole with the SEC. She claimed OCT No. 8257, the owner’s copy, was in their possession and that Galvez deviously acquired a new title. She also stated that tax declarations bore the name of Felicisima Pineda as Administrator of the property for the church. She denied receiving a valid demand to vacate and argued that Galvez had previously voluntarily vacated the lot in a prior ejectment case, indicating he had no right over it.
The MeTC ruled in favor of petitioner, ordering respondent to vacate. The Regional Trial Court (RTC) and the Court of Appeals (CA) affirmed the MeTC decision. The CA held that petitioner sufficiently established its cause of action for unlawful detainer and that respondent’s claims of ownership did not divest the MeTC of jurisdiction.

ISSUE

Whether the Court of Appeals erred in affirming the lower courts’ decisions which upheld petitioner’s right to recover possession of the subject property in an action for unlawful detainer.

RULING

The Supreme Court DENIED the petition and AFFIRMED the assailed Court of Appeals Decision and Resolution. The Court held that the MeTC had jurisdiction over the unlawful detainer case. Petitioner sufficiently alleged in its Complaint that respondent’s possession of the property was by mere tolerance, which ended upon the service of the demand to vacate on February 12, 2007. The filing of the Complaint on March 26, 2007 was within the one-year period from the date of last demand required by the Rules. The action was therefore properly within the MeTC’s jurisdiction. The Court ruled that the issue of ownership raised by respondent need not be resolved definitively in an ejectment suit; it is enough that the issue of possession is settled. Petitioner presented OCT No. (8257) M-35266 in its name, which is prima facie evidence of its ownership and right to possess. Respondent’s claim of a separate OCT No. 8257 in the name of “Iglesia De Jesucristo Jerusalem Nueva of Manila, Philippines, Inc.” (the same name as petitioner) did not conclusively prove a superior right. The dorsal entry of OCT No. (8257) M-35266 indicated it was a transfer from OCT No. 8257, but this did not invalidate petitioner’s title. The unlawful detainer case was a proper remedy to determine who had a better right of possession based on the evidence presented.