Hilario v. CA

G.R. No. 121865 (August 7, 1996)

SC upholds Hilarios' eviction of Palileo and Anastacio despite ownership disputes.

Facts:

The case revolves around a dispute concerning a house and lot in Poblacion, Guiguinto, Bulacan, which was sold by spouses Rosauro Palileo and Josefina Anastacio (private respondents) to spouses Cesar Hilario (now deceased) and Antonia Hilario (petitioners) under a deed of sale dated March 5, 1986. The sale included a provision allowing the vendors to repurchase the property within one year. Following the sale, the Hilarios allowed the private respondents to remain in possession of the property based on a verbal agreement that they would vacate the premises after two years. However, the private respondents did not vacate after the agreed period, prompting the Hilarios to file a complaint for unlawful detainer on August 12, 1993.

In their defense, the private respondents contended that the deed of sale was actually a deed of mortgage, claiming that their obligation had been fulfilled through payment of P165,000. They argued that they remained the owners of the property and that their continued possession supported their assertion. They also challenged the jurisdiction of the municipal trial court over the case, although they did not provide substantial arguments to support this claim.

The municipal trial court ruled in favor of the Hilarios, affirming its jurisdiction and determining that the deed of conveyance was a valid sale, thus granting the Hilarios ownership and possession of the property. The court ordered the private respondents to vacate the premises and pay attorney's fees. The private respondents appealed to the Regional Trial Court, which upheld the municipal court's decision. They subsequently appealed to the Court of Appeals, which reversed the lower courts' rulings, dismissing the complaint for ejectment on the grounds that the issue of ownership was central to the case.

Legal Issues:

The primary legal issue in this case is whether the jurisdiction of the municipal trial court was affected by the private respondents' claim of ownership, which was based on their assertion that the deed of sale was, in fact, a mortgage contract. The case also raises questions about the nature of ejectment proceedings and the extent to which issues of ownership can be addressed in such cases.

Arguments:

  • Petitioners' Arguments: The Hilarios argued that the municipal trial court had jurisdiction over the unlawful detainer case, as the complaint sufficiently alleged unlawful possession. They maintained that the deed of sale was valid and that the private respondents had no right to remain in possession after the expiration of the agreed period. They contended that the issue of ownership raised by the private respondents did not divest the court of its jurisdiction.

  • Respondents' Arguments: The private respondents contended that the deed of sale was actually a mortgage, and thus they remained the rightful owners of the property. They argued that the municipal trial court lacked jurisdiction because the case involved a question of ownership, which should be resolved before any determination of possession could be made.

Court's Decision and Legal Reasoning:

The Supreme Court reversed the decision of the Court of Appeals, reinstating the judgments of the municipal trial court and the Regional Trial Court. The Court emphasized that the jurisdiction of the municipal trial court over forcible entry and unlawful detainer cases is not lost even if the defendant raises an issue of ownership. The Court reiterated that the inferior courts can resolve ownership issues provisionally, solely for the purpose of determining possession.

The Court highlighted that the allegations in the Hilarios' complaint sufficiently established the jurisdictional facts necessary for the municipal trial court to hear the case. It noted that the mere assertion of ownership by the private respondents did not divest the court of its jurisdiction, as the nature of the action was primarily about possession, not ownership. The Court also pointed out that the private respondents had other remedies available to assert their ownership, such as filing a separate action for reconveyance.

Significant Legal Principles Established:

  1. Jurisdiction in Ejectment Cases: The jurisdiction of municipal trial courts over forcible entry and unlawful detainer cases is not affected by the interjection of ownership issues. Courts can resolve ownership issues provisionally to determine possession.

  2. Nature of Ejectment Proceedings: Ejectment cases focus on the issue of physical possession (possession de facto) rather than legal ownership (possession de jure). The allegations in the complaint must sufficiently establish the basis for the court's jurisdiction.

  3. Provisional Adjudication of Ownership: Any adjudication regarding ownership in the context of ejectment proceedings is provisional and does not bar subsequent actions regarding the title to the property.