GR L 57348; (May, 1985) (Digest)
G.R. No. L-57348. May 16, 1985.
FRANCISCO DEPRA, plaintiff-appellee, vs. AGUSTIN DUMLAO, defendant-appellant.
FACTS
Plaintiff-appellee Francisco Depra is the registered owner of a parcel of land. Defendant-appellant Agustin Dumlao owns an adjoining lot. In 1972, it was discovered that Dumlao’s kitchen encroached on 34 square meters of Depra’s property. Depra’s mother filed an action for unlawful detainer in the Municipal Court of Dumangas. The Municipal Court, finding Dumlao a builder in good faith, applied Article 448 of the Civil Code and ordered the creation of a “forced lease” over the encroached area, with Dumlao to pay monthly rent. Neither party appealed this judgment. Depra, however, refused to accept the tendered rentals. Subsequently, Depra filed a Complaint for Quieting of Title before the Court of First Instance of Iloilo over the same 34-square-meter portion. Dumlao asserted the defense of res judicata, contending the Municipal Court’s final decision barred the new action.
ISSUE
The primary issue is whether the Municipal Court’s decision in the unlawful detainer case constitutes a valid and conclusive judgment that bars the subsequent action for quieting of title.
RULING
The Supreme Court ruled that the Municipal Court’s decision was null and void and could not operate as res judicata. The legal logic is twofold. First, the Municipal Court exceeded its jurisdiction. Under the Rules of Court, a judgment in a detainer case is conclusive only on the issue of possession. By imposing a “forced lease,” the court adjudicated an interest in real property, which is beyond its jurisdiction and exclusively within the original jurisdiction of Courts of First Instance (now Regional Trial Courts). A judgment rendered without jurisdiction is void and produces no legal effect. Second, even assuming a valid judgment, res judicata would not apply due to a difference in causes of action. The detainer case involved deprivation of possession, while the quieting of title suit is founded on ownership. Section 7, Rule 70 of the Rules of Court explicitly states that a judgment in a detainer case shall not bar an action between the same parties respecting title to the land. The Court, giving effect to the parties’ stipulation that Dumlao was a builder in good faith, applied Article 448 of the Civil Code. It set aside the Trial Court’s order and remanded the case for further proceedings to determine the applicable remedies under Article 448, such as whether Depra would appropriate the kitchen or oblige Dumlao to pay the price of the land, with provisions for reasonable rent in the interim.