GR 32626; (January, 1971) (Digest)
G.R. No. L-32626. January 28, 1971.
POLICARPIA TIU, assisted by her husband CHOA THIAN, petitioner, vs. THE HONORABLE COURT OF APPEALS (SPECIAL SECOND DIVISION) and CHOA KIM, respondents.
FACTS
Policarpia Tiu filed an ejectment suit against Choa Kim in the City Court of Manila, which ruled in her favor, ordering Kim to vacate the premises and pay arrears. Kim appealed to the Court of First Instance (CFI), which affirmed the city court’s decision. Kim then appealed to the Court of Appeals. Tiu moved to dismiss this appeal, arguing it was frivolous and dilatory. The Court of Appeals’ Special Second Division, by a 3-2 vote, denied the motion to dismiss. Tiu thus elevated the matter to the Supreme Court via certiorari.
The core factual dispute centers on Kim’s defense. He admitted the existence and expiration of the lease contract but contested Tiu’s ownership of the property, alleging she was not a Filipino citizen. His continued occupancy and appeal were premised solely on this challenge to Tiu’s title.
ISSUE
Whether the Court of Appeals committed a grave abuse of discretion in not dismissing Choa Kim’s appeal, given that his sole defense—challenging the lessor’s ownership—is legally impermissible in an ejectment suit.
RULING
The Supreme Court granted the petition, set aside the Court of Appeals’ resolution, and ordered the dismissal of Kim’s appeal. The legal logic is clear and grounded in established procedural and substantive principles governing ejectment cases. An action for ejectment based on the expiration of a lease is summary in nature, designed to provide a swift remedy for possession. The only essential elements are the fact of the lease and the expiration of its term. The plaintiff-lessor is not required to prove ownership, and the defendant-lessee is estopped from denying the lessor’s title at the commencement of the landlord-tenant relationship, as codified in Section 3, Rule 131 of the Rules of Court.
Here, Kim admitted the lease and its expiry. His defense, challenging Tiu’s ownership, is therefore foreign and irrelevant to the ejectment proceedings. Evidence on ownership is admissible only to determine the character of possession or compute damages, not to litigate title. By raising an unavailable and unsubstantial defense, Kim’s appeal was deemed frivolous and prosecuted manifestly for delay. Public policy demands the expeditious resolution of ejectment cases, and allowing such an appeal to proceed would defeat this objective. Consequently, the Court of Appeals’ failure to dismiss it constituted a grave abuse of discretion warranting corrective action. The other procedural issues raised were rendered moot by this dispositive finding.