GR 239979; (February, 2020) (Digest)
G.R. No. 239979 , February 17, 2020
MRS. CONSOLACION V. TIÑA, PETITIONER, VS. STA. CLARA ESTATE, INC., RESPONDENT.
FACTS
The case involves a dispute over a 231-square-meter lot along Creek I (Ogumod Creek) in Bacolod City. Petitioner Consolacion V. Tiña claimed that she and her husband had been occupying the property openly, adversely, and continuously for over 55 years. She filed a Miscellaneous Sales Application, which was approved by the DENR in 1997. Respondent Sta. Clara Estate, Inc. claimed ownership, presenting Transfer Certificate of Title (TCT) No. T-28629 registered in its name since 1965, and alleged that petitioner was illegally occupying a portion of its property. Respondent filed an ejectment case before the MTCC, which ruled in its favor, a decision affirmed by the RTC, the Court of Appeals, and finally by the Supreme Court in a Resolution dated September 21, 2015. An Entry of Judgment was issued. Meanwhile, petitioner filed a separate Complaint for cancellation of title before the RTC (Civil Case No. 00-11133). During its pendency, respondent filed a Motion to Dismiss, arguing that the Supreme Court had already resolved the issue of Creek I’s nature (as man-made and belonging to respondent) in the ejectment case. The RTC granted the motion and dismissed the case. Petitioner filed a direct petition for review on certiorari before the Supreme Court.
ISSUE
Whether the Regional Trial Court erred in dismissing the Complaint for cancellation of title based solely on the ruling on ownership made in the related ejectment case.
RULING
Yes. The Supreme Court granted the petition, reversed the RTC’s Resolution and Order, and remanded the case for further proceedings. The Court held that while the sole issue in ejectment cases is possession, the issue of ownership may be resolved if it is intertwined with the issue of possession. However, any adjudication of ownership in an ejectment case is merely provisional and ancillary to resolving possession; it is not final and binding on a separate action involving title to the property. A separate action to directly attack the validity of a title, such as the complaint for cancellation of title filed by petitioner, is the proper venue to definitively resolve questions of ownership. Therefore, the RTC erred in dismissing Civil Case No. 00-11133 based on the ruling in the ejectment case. The case was remanded to the RTC to proceed with the determination of who is the rightful owner of the disputed property.