G.R. No. 237201 , September 22, 2020
MARIA VICTORIA A. REYES, PETITIONER, VS. ISABEL MENDOZA MANALO, CELSO MENDOZA, JOSEPHINE GONZALES, ISAGANI BLANCO, AND ALL PERSONS ACTING FOR AND IN THEIR BEHALF, RESPONDENTS.

FACTS

Petitioner Maria Victoria A. Reyes, a co-owner of a parcel of land in Pinamalayan, Oriental Mindoro, filed an unlawful detainer complaint against respondents before the Municipal Trial Court (MTC). She alleged that her family tolerated the respondents’ occupation of portions of the property for years, with the understanding they would vacate upon demand. In February 2014, she inspected the property and later sent demand letters in April and July 2014 for respondents to vacate. Upon their refusal, she filed the ejectment case. Respondents failed to file their Answers within the 10-day reglementary period under Rule 70, filing them 33 days late. The MTC granted Reyes’s motion for judgment and ruled in her favor, a decision affirmed by the Regional Trial Court (RTC).

ISSUE

Whether the Court of Appeals correctly reversed the lower courts and remanded the case for trial as an action for recovery of possession and ownership, despite respondents’ late filing of their Answers.

RULING

Yes, the Supreme Court affirmed the Court of Appeals. The core legal logic hinges on the nature of the action and the substantive issues raised. While procedural rules mandate a strict 10-day period to answer in ejectment cases, the Court found that the respondents’ defenses in their belated Answers fundamentally transformed the case. They asserted ownership through acquisitive prescription, claiming open, continuous, exclusive, and notorious possession for over thirty years. This assertion directly placed the issue of ownership in genuine controversy. An unlawful detainer action, being summary, only determines physical or de facto possession and cannot adjudicate claims of ownership. When the issue of ownership is so intertwined with possession that its resolution is necessary to settle the possession issue, the case ceases to be a simple ejectment suit. Consequently, the proper remedy is a plenary action for recovery of possession (accion reivindicatoria) cognizable by the RTC. The Court held that remanding the case for trial on the merits served the higher interest of substantial justice, as a summary proceeding would deprive the parties of a full opportunity to prove their claims regarding ownership. The procedural lapse of late filing was thus excused to allow a complete adjudication of the substantive rights involved.