Monday, January 25, 2016

Spouses Manila vs. Spouses Manzo [GR No. 163602, September 7, 2011]

FACTS: On 30 June 1982, respondent Ederlinda Gallardo leased two parcels of land in Las Pinas to petitioner Eulogia Manila for a period of ten years. They also agreed that the lease shall have the option to buy the property within two years from the date of execution of the contract of lease. The contract of lease expired on 01 July 1992 but the lessee continued in possession of the property despite a formal demand letter dated 08 August 1992. The petitioner, on the other hand, contends that she became the owner of the property at the time she communicated to the plaintiff her desire to exercise the option to buy the said property.

Then, an action for ejectment was filed by the respondents against the petitioners. The MeTC ruled in favor of the respondents. When the petitioners appealed the case to the RTC, the latter ordered the herein respondents to execute a deed of absolute sale over the subject lot in favor of the herein petitioners after full payment of purchase price. As a result, the herein respondents question such decision and contend that RTC's appellate jurisdiction in ejectment cases is limited to the determination of who is entitled to the physical possession of real property and that the judgment is conclusive only on the issue of possession and does not affect the ownership of the land. The CA reinstated the decision of MeTC. Hence, this petition.

ISSUE: Whether or not the Court may delve into the issue of ownership in an ejectment case

RULING: While the Court in an ejectment case may delve on the issue of ownership or possession de jure solely for the purpose of resolving the issue of possession de facto, it has no jurisdiction to settle with finality the issue of ownership and any pronouncement made by it on the question of ownership is provisional in nature. A judgment in a forcible entry or detainer case disposes of no other issue than possession and establishes only who has the right of possession, but by no means constitutes a bar to an action for determination of who has the right or title of ownership. It cannot adjudicate with semblance of finality the ownership of the property to either party by ordering the cancellation of the TCT.

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