GR L 43427; (August, 1982) (Digest)
G.R. No. L-43427 August 30, 1982
FELIPE N. CRISOSTOMO, petitioner, vs. HONORABLE COURT OF APPEALS, EXEQUIEL CRUZ, CELERINO GINES, JESUS BELLO, JOSEFINA DE BORJA, PRIMO VICTORIANO, PACITA VILORIA, EUGENIO ARRIOLA, and JOSE AQUINO, respondents.
FACTS
Petitioner Felipe Crisostomo, the registered owner of parcels of land in Pasig, Rizal, filed an ejectment suit against the respondents. Crisostomo acquired the property through a deed of transfer from Apolinario Castillo, who had purchased it from the previous registered owner, Dorotea Gonzales. The respondents were occupying the land, claiming to have leased separate portions from Dorotea Gonzales. After acquiring title, Crisostomo demanded that the respondents vacate. Upon their refusal, he initiated the ejectment action. Meanwhile, Gonzales and her children filed a separate civil case seeking the annulment of the sale to Castillo and the subsequent transfer to Crisostomo. This annulment case was pending appeal at the Court of Appeals during the proceedings of the ejectment suit.
ISSUE
Whether the respondents, as lessees of the former owner, can be lawfully ejected by the petitioner, the current registered owner, despite the pendency of a separate action challenging the validity of his title.
RULING
The Supreme Court ruled in favor of the petitioner and reversed the Court of Appeals. The legal logic is anchored on the principle that a Torrens title is conclusive evidence of ownership. As the registered owner under Transfer Certificate of Title No. 169446, Crisostomo has the right to possess the property. The pendency of an action for annulment of the sale does not paralyze this right or suspend the ejectment proceedings. An action for ejectment is fundamentally a possessory action, and the petitioner’s certificate of title furnishes a sufficient basis for recovering possession. The respondents’ claim of a leasehold relationship with the former owner does not constitute a superior right that can override the registered title. Their proper recourse, if they have any claim against the petitioner, is a separate personal action for damages, not a defense to withhold possession. The Court emphasized that the respondents’ continued occupation after the demand to vacate constituted unlawful detainer. Therefore, the petitioner is entitled to possession and the accrued rentals as determined by the lower courts.