G.R. No. 220220 . August 15, 2018.
PHILIPPINE INDEPENDENT CHURCH, PETITIONER, VS. BISHOP MARTIN BASAÑES, RESPONDENT.

FACTS

The Philippine Independent Church (PIC) filed an unlawful detainer case against Fr. Ramon Dollosa, later substituted by Bishop Martin Basañes, seeking to recover possession of a church and convent in Pulupandan, Negros Occidental. Petitioner PIC claimed ownership by virtue of a 1903 donation from the original owner, Catalino Riego Magbanua, later formalized by his heirs in a 2001 Deed of Donation. The property had been occupied by PIC clergy until a faction led by Msgr. Macario V. Ga separated in the 1980s, with respondent Basañes belonging to this group. After Fr. Dollosa allegedly violated an agreement, PIC demanded he vacate the premises.
Respondent Basañes, representing the separate Philippine Independent Catholic Church (PICC), contested the action, asserting a superior claim of ownership. He presented a conflicting 2005 Deed of Donation executed by a different set of individuals claiming to be Catalino’s legitimate heirs, donating the same property to PICC. The Municipal Circuit Trial Court (MCTC) ruled in favor of PIC, finding its prior possession was by tolerance, a decision affirmed by the Regional Trial Court (RTC). The Court of Appeals (CA) reversed, holding that both parties derived rights from different sets of heirs, making them co-owners; thus, PIC had no cause of action for unlawful detainer against a co-owner.

ISSUE

Whether the Court of Appeals erred in dismissing the unlawful detainer complaint on the ground that petitioner and respondent are co-owners of the disputed property.

RULING

Yes, the Supreme Court reversed the CA and reinstated the MCTC and RTC decisions. The Court clarified that an unlawful detainer suit is a quieting process that merely determines who has a better right of material possession (possession de facto), not ownership. The CA erred in delving into the question of ownership and co-ownership, which is irrelevant to the summary nature of ejectment proceedings. The only relevant facts are the character of petitioner’s possession and the manner of respondent’s entry.
The evidence established that PIC had prior physical possession of the property since the early 1900s, built the structures, and tolerated the occupancy of its clergy, including respondent’s predecessor. Respondent’s entry and continued possession were by virtue of this tolerance as a member of the PIC before the schism. His subsequent claim of a separate donation and formation of a distinct religious entity did not negate the juridical fact that his initial possession was derivative and permissive. Upon PIC’s withdrawal of tolerance through a demand to vacate, respondent’s possession became unlawful. The conflicting claims of donation and ownership raised by respondent constitute a collateral issue that must be resolved in a separate action for title, not in an ejectment case where prior possession and loss of tolerance are sufficiently proven.