G.R. No. L-60544 May 19, 1984
ARSENIO FLORENDO, JR., MILAGROS FLORENDO and BEATRIZ FLORENDO, petitioners, vs. HON. PERPETUA D. COLOMA, Presiding Judge of Branch VII, City Court of Quezon City; GAUDENCIO TOBIAS, General Manager, National Housing Authority; Registrar of Deeds for Quezon City; WILLIAM R. VASQUEZ and ERLINDA NICOLAS, respondents.

FACTS

Adela Salindon, an awardee of a lot from the Philippine Homesite and Housing Corporation (PHHC), filed an ejectment complaint in 1969 against respondents William Vasquez and Silverio Nicolas (later substituted by his wife Erlinda) before the Quezon City Court. She alleged they were squatters on her titled property. The defendants claimed adverse possession since 1950, contested Salindon’s qualification to purchase the lot, and challenged the court’s jurisdiction, arguing the case involved questions of title. The PHHC, impleaded in a third-party complaint, defended the validity of its sale to Salindon and also questioned the city court’s jurisdiction over actions affecting title.
The City Court rendered a decision in 1975, not only dismissing the ejectment but also declaring the PHHC’s sale to Salindon null and void and ordering the PHHC to award the lot to the defendants. Salindon appealed to the Court of Appeals but died during the pendency of the appeal without substitution. The appeal was eventually dismissed for abandonment. Subsequently, Salindon’s heirs (the petitioners) inherited the lot and secured a new title. The City Court then issued a writ of execution and an order directing the Register of Deeds to annul the titles held by Salindon and the petitioners to enforce its 1975 decision.

ISSUE

Whether the Quezon City Court acted with grave abuse of discretion and in excess of its jurisdiction in rendering a decision that adjudicated ownership and ordered the cancellation of certificates of title in an ejectment case.

RULING

Yes. The Supreme Court nullified the City Court’s decision, writ of execution, and order for cancellation of titles. The legal logic is anchored on the fundamental principle of jurisdiction. An ejectment case, under the summary procedure governing city courts at the time, is designed solely to resolve the issue of physical possession (possession de facto) and cannot adjudicate questions of ownership or title. The City Court’s jurisdiction was limited to determining who had a better right of possession.
By declaring the PHHC sale to Salindon null and void, ordering the PHHC to award the lot to the defendants, and subsequently commanding the cancellation of transfer certificates of title, the City Court arrogated unto itself the power to resolve issues of ownership, a matter exclusively within the original jurisdiction of the then Court of First Instance (now Regional Trial Court). This constituted a clear act in excess of jurisdiction and grave abuse of discretion. Furthermore, the Supreme Court emphasized that the defendants, as alleged squatters on government property (the PHHC/NHA being a government agency), could not acquire vested rights or lawful ownership through their unauthorized occupation, regardless of its duration. Any potential rights they might have under government relocation programs were for the NHA, not the city court, to determine. Consequently, ownership of the disputed lot was declared to remain with the National Housing Authority.