GR L 43726; (August, 1988) (Digest)
G.R. No. L-43726 August 15, 1988
CHURCH OF CHRIST, DADIANGAS CONGREGATION, INC., represented by LAUREANO N. BELO, et al., petitioner, vs. SPOUSES PELEGRINO VALLESPIN and ROSALIA VALLESPIN and HON. PEDRO SAMSON ANIMAS, respondents.
FACTS
The petitioner, Church of Christ, Dadiangas Congregation, Inc., filed an unlawful detainer case against the respondent spouses. The property involved is a public land subject of a sales application filed in 1957 by Laureano N. Belo for the benefit of the Church of Christ. The respondents, originally members of the church, were allowed in 1964 to transfer and later construct a house on the lot with the understanding they would vacate upon demand. In 1968, the respondents were expelled from the congregation for doctrinal differences. After demands to vacate were refused, the petitioner filed the ejectment suit in the City Court, which ruled in its favor, ordering the respondents to vacate and remove their house.
On appeal, the Court of First Instance reversed the City Court’s decision and dismissed the complaint. The CFI held that the Church of Christ (N.T.), represented by Domingo H. Cruz—a rival faction which also claimed rights over the lot pursuant to a Board of Liquidators resolution subdividing it—was an indispensable party that was not impleaded. The respondents argued they occupied the lot with the permission of this other church faction, not the petitioner.
ISSUE
The main issue is whether the ejectment complaint should be dismissed for failure to implead the Church of Christ (N.T.) as an indispensable party.
RULING
The Supreme Court reversed the CFI decision and reinstated the City Court’s judgment, with modification. The legal logic is twofold. First, on the procedural issue, the Court ruled that in an ejectment suit, one co-owner can validly file the action to recover possession without joining all other co-owners, pursuant to Article 487 of the Civil Code. The petitioner, as a recognized co-owner per the Board of Liquidators resolution, had the legal personality to sue for ejectment alone. The CFI thus erred in dismissing the complaint for non-joinder of the other church faction.
Second, the Court addressed the substantive developments. It noted that the respondents had already vacated the house before the appeal, rendering the possessory aspect of the ejectment case moot. The remaining live issue was the ownership of the house itself, which the City Court had ordered removed. The Supreme Court clarified that the determination of ownership of the structure is beyond the jurisdiction of an ejectment court, which is limited to deciding the issue of possession. Therefore, while the CFI was correct that ownership was intertwined, it erred in dismissing the case on a procedural ground instead of upholding the possessory remedy. The Supreme Court reinstated the ejectment judgment but eliminated the City Court’s ruling on lot ownership, reserving that issue for a proper action in the correct forum. The decision emphasizes the summary nature of ejectment and the separate remedies for possession and ownership.