G.R. No. 243896 . July 15, 2020.
ARACELI REBURIANO, PETITIONER, VS. AUGUSTUS “JOJIT” DE VERA, RESPONDENT.

FACTS

Petitioner Araceli Reburiano sold a parcel of land to Ruth De Vera, mother of respondent Augustus “Jojit” De Vera, for US$60,000.00 payable in installments. Due to Ruth’s failure to pay the full price, the parties agreed to rescind the sale on January 17, 2004, with Reburiano agreeing to refund US$20,000.00 of the installments paid, and Ruth agreeing to vacate the property. Ruth and Jojit failed to vacate. Reburiano filed an unlawful detainer case. The Municipal Trial Court (MTC) rendered an Amended Decision on July 27, 2006, ordering Jojit to vacate and pay reasonable compensation, and ordering Reburiano to refund US$20,000.00 to Ruth/Jojit, less the compensation due. The MTC stated that eviction would only occur after the monetary dispositions were satisfied. Reburiano deposited US$13,500.00 with the MTC, deducting compensation for use. Jojit moved for execution. The MTC issued a Writ of Execution. The sheriff levied upon the subject property itself (TCT No. 540832) for the alleged judgment debt of US$20,000.00 and sold it at public auction to Jojit in 2009. Reburiano filed a Complaint for Quieting of Title. The Regional Trial Court (RTC) dismissed the complaint, ruling she lost title due to the auction sale. The Court of Appeals affirmed. Reburiano elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the MTC, in an unlawful detainer case, had jurisdiction to order the levy and sale of the property itself (the subject matter of the detainer) to satisfy a monetary judgment for the refund of the purchase price.

RULING

The Supreme Court GRANTED the petition. The MTC’s Amended Decision, insofar as it ordered the levy and sale of the property to satisfy the monetary judgment for the refund, was declared null and void for lack of jurisdiction. The Court held that in an unlawful detainer case, the MTC’s jurisdiction is limited to the issue of physical possession. Any monetary awards are merely incidental and ancillary to the issue of possession. The MTC has no jurisdiction to adjudicate claims of ownership or to enforce its monetary judgment by levying upon the property itself, which is the res of the ejectment case. The levy and sale of the property constituted an invalid execution beyond the MTC’s jurisdiction. The proper remedy for Jojit to enforce the monetary judgment was a separate civil action. The Court set aside the CA and RTC decisions, declared the Writ of Execution, Notice of Levy, and Certificate of Sale null and void, and ordered the cancellation of their annotations on the title. The Court ordered mutual restitution: Jojit to return ownership of the property to Reburiano, and Reburiano to return the US$20,000.00 refund, less the reasonable rent in arrears owed by Jojit.