G.R. No. L-77976 November 24, 1988
MAXIMO GABRITO, ROGER LIBUT, CARMELITA UY, LIZA DE VERA, thru her Attorney-in-Fact, JESUS DE LOS SANTOS, petitioners, vs. THE HON. NINTH DIVISION, COURT OF APPEALS, THE HON. NICIAS O. MENDOZA, Presiding Judge Branch 74, Regional Trial Court, Olongapo City, ET AL., respondents.

FACTS

Private respondents, the spouses Roberto Tan and Benita Ching-Tan, filed an unlawful detainer complaint against petitioners Maximo Gabrito, et al., before the Municipal Trial Court of Olongapo City. The Tans alleged they were the possessors and legal owners of a parcel of land in Olongapo City, as evidenced by a Tax Declaration, and that petitioners were their lessees. The Tans notified petitioners in January 1984 of their intention to personally use the land to build their house, giving them three months to vacate. Petitioners initially requested and were granted an extension but subsequently stopped paying rentals. After failed barangay conciliation, the Tans filed the ejectment case.
In their defense, petitioners claimed they were builders in good faith, that the land was public land not yet titled, and that the Tans’ predecessors-in-interest had no valid title. They argued the sale to the Tans violated P.D. No. 1517 as they, being lessees, had a right of first refusal. The Municipal Trial Court ruled for the Tans, ordering petitioners to vacate and pay accrued rentals and attorney’s fees. The Regional Trial Court and the Court of Appeals affirmed the decision.

ISSUE

Whether the courts have jurisdiction over the unlawful detainer case despite the unresolved issue of ownership involving public land.

RULING

Yes, the courts properly exercised jurisdiction. The Supreme Court affirmed the decision of the Court of Appeals, holding that an ejectment suit is fundamentally a possessory action. Its primary objective is to determine who has a better right of physical possession (possession de facto), independent of the question of ownership. Jurisdiction in such cases is conferred by law upon the proper municipal or regional trial courts based on the allegations of the complaint and the relief sought.
The Court clarified that the principle of exhaustion of administrative remedies, which requires prior recourse to agencies like the Bureau of Lands for controversies over public land disposition, does not apply to purely possessory actions. This principle is confined to controversies arising from the disposition, alienation, or determination of rival claims to ownership of public lands. It does not bar an action whose sole aim is to determine who has the actual, physical possession or occupation of the property. The Bureau of Lands itself, in a related decision, admitted the jurisdiction of the courts to decide the question of physical possession, though not ownership. Therefore, the lower courts correctly proceeded to resolve the ejectment case based on the Tans’ prior possession and the expiration of the petitioners’ right to occupy the land, without needing to wait for a final administrative adjudication on title.