G.R. No. L-49793 August 20, 1981
EMETERIO IPAPO, petitioner, vs. COURT OF APPEALS, GRACIOSO GERONIMO and LYDIA GERONIMO, respondents.

FACTS

Emeterio Ipapo appealed from a Court of Appeals decision affirming a lower court judgment. That judgment held spouses Gracioso and Lydia Geronimo entitled to possession of a 2,353-square-meter portion of Lot No. 2090 in Meycauayan, Bulacan. Ipapo was ordered to vacate the land and pay monthly rentals plus attorney’s fees to the Geronimos. The case was submitted for Supreme Court decision without the private respondents’ brief.
Subsequently, petitioner’s counsel filed a manifestation informing the Court of a new development. Judge Eduardo P. Caguioa of the Court of First Instance of Bulacan had rendered a decision in a separate accion de reinvindicacion (Civil Case No. 780-V), entitled “Emeterio Ipapo vs. Gracioso Geronimo, et al.” This September 23, 1980 decision declared the disputed land, identified as part of the same Lot No. 2090, to be of the sole and exclusive ownership of plaintiff Emeterio Ipapo. While this ownership decision was not yet final and executory, no appeal had been interposed by the Geronimo spouses.

ISSUE

Whether the Supreme Court appeal from the forcible entry judgment should be dismissed in light of the subsequent trial court decision declaring Ipapo the owner of the disputed property.

RULING

Yes, the appeal is dismissed. The legal logic is grounded in the doctrine of mootness and the hierarchical relationship between possessory and proprietary actions. The instant appeal arose from a judgment in a forcible entry case, which is a purely possessory action designed to resolve only the issue of physical possession (possession de facto). It does not adjudicate ownership. The subsequent decision in the accion de reinvindicacion, an action for recovery of ownership, directly addressed the proprietary title to the very same land. Although that ownership decision was not yet final, its issuance fundamentally altered the situation.
A judgment in an ownership case, once final, supersedes and controls the outcome of any prior possessory action over the same property. The pendency of this appeal on a purely possessory matter was rendered academic and pointless by the trial court’s definitive ruling on the ultimate issue of ownership in favor of Ipapo. To continue with the appeal would be an inefficient use of judicial resources, as any ruling on possession would be contingent upon and potentially overturned by the final outcome of the ownership case. Therefore, the Supreme Court dismissed the case as moot and academic.