The Supreme Court ruled that a Municipal Trial Court (MTC) has jurisdiction over an ejectment case even when the defendant claims ownership of the property. The Court emphasized that the MTC can provisionally resolve the issue of ownership to determine the right of possession. This decision clarifies that a simple claim of ownership does not automatically strip the lower court of its authority to hear eviction cases, ensuring quicker resolution of possessory disputes.

When Tolerance Turns Tenancy: Resolving Possession Amidst Ownership Claims

The case of Romualdo C. Perez versus Apolonio Cruz centers around a contentious ejectment case initially filed by Cruz against Perez. Cruz claimed ownership of a residential lot in Hagonoy, Bulacan, asserting that Perez was occupying a portion of the land with his permission, a tolerance that later ended when Cruz sought to reclaim the property. Perez, however, contested Cruz’s ownership, claiming he inherited the land from his grandmother and had been in continuous possession. This dispute raised a critical question: Does a claim of ownership in an ejectment case automatically divest the Municipal Trial Court of its jurisdiction?

The legal framework surrounding ejectment cases, specifically unlawful detainer, hinges on the initial possession being lawful, based on permission or tolerance, which subsequently expires or is withdrawn. In this context, the core issue becomes whether the defendant’s possession is indeed based on the plaintiff’s tolerance, as alleged in the complaint. The Supreme Court has consistently held that jurisdiction is determined by the allegations in the complaint. Here, Cruz’s complaint explicitly stated that Perez was allowed to build his house on the land due to their familial relationship, indicating possession based on tolerance.

Petitioner Perez relied on the case of Velez v. Avelino to bolster his claim that the Municipal Trial Court had no jurisdiction over the case as it pertained to ownership rather than merely possession. However, the Supreme Court rejected this argument by pointing to the more recent case of Banco de Oro Savings and Mortgage Bank v. Court of Appeals, which clarified that if a person occupies land by tolerance without any contract and with the implied promise that they will vacate upon demand, a summary action for ejectment is the proper remedy if they fail to do so.

Furthermore, the Court referenced Dehesa v. Macalalag, which established that a defendant in an ejectment case cannot simply claim ownership to deprive the court of jurisdiction. Rule 70, Section 16 of the Revised Rules of Court provides that when ownership is raised as a defense, the court shall resolve the issue of ownership only to determine the issue of possession. This determination, however, is not conclusive and does not prevent parties from pursuing their claims of ownership in a separate, appropriate action.

The factual backdrop revealed further complications. Besides conflicting tax declarations, Cruz presented a notarized Deed of Sale indicating Perez had sold the land to Cruz’s mother. While Perez alleged forgery, the State Prosecutor dismissed the criminal case he filed due to lack of evidence. The Regional Executive Director of the DENR also sustained Cruz’s opposition to Perez’s survey application, further supporting Cruz’s claim.

In its analysis, the Supreme Court highlighted the DENR’s factual findings, emphasizing that administrative agencies’ factual findings are binding on the courts if supported by substantial evidence. The Court noted that Perez failed to overcome the presumption of regularity of the notarized Deed of Sale. The Court stated that its role isn’t to re-evaluate the evidence submitted to the administrative agency and substitute its own judgment, a principle rooted in the doctrine of separation of powers and respect for administrative expertise.

Ultimately, the Supreme Court affirmed the Court of Appeals’ decision, which upheld the Municipal Trial Court’s judgment in favor of Cruz. While the Court acknowledged the unresolved question of ownership, it stressed that the DENR provides an initial forum for resolving such disputes. The High Tribunal ultimately found that Cruz successfully demonstrated his right to retain possession of the contested land. The Court clarified that, while a claim of ownership doesn’t automatically divest an inferior court of jurisdiction over an ejectment case, it is necessary to tackle the issue of ownership administratively before seeking judicial pronouncements of ownership with finality.

FAQs

What was the key issue in this case?	The central issue was whether the Municipal Trial Court (MTC) had jurisdiction over an ejectment case when the defendant claimed ownership of the property.
What is unlawful detainer?	Unlawful detainer is a legal action to recover possession of property initially held lawfully (e.g., by permission or tolerance) but is now being withheld unlawfully after the permission has been withdrawn.
How is jurisdiction determined in ejectment cases?	Jurisdiction is determined by the allegations in the complaint. If the complaint alleges unlawful detainer, the MTC typically has jurisdiction, even if the defendant raises ownership as a defense.
Can a court resolve ownership issues in an ejectment case?	Yes, but only to determine the issue of possession. Any determination on ownership is provisional and not a final adjudication of title.
What is the effect of a notarized Deed of Sale?	A notarized Deed of Sale carries a presumption of regularity. The burden of proof to overcome this presumption rests on the party challenging its validity, requiring clear and convincing evidence.
What is the role of the DENR in land disputes?	The DENR plays a crucial role in resolving land disputes, especially those involving untitled lands. It conducts surveys, processes land applications, and makes initial determinations on ownership claims.
Are the findings of fact of an administrative agency binding on the courts?	Yes, the factual findings of administrative agencies, like the DENR, are generally binding on the courts if supported by substantial evidence.
What happens if an ejectment case involves untitled land?	The parties may need to pursue administrative remedies with the DENR to resolve ownership claims before seeking a final judicial determination of title.

The Supreme Court’s decision in Perez v. Cruz underscores the principle that possession and ownership, while often intertwined, are distinct legal concepts. It clarifies that a simple claim of ownership does not automatically divest the MTC of jurisdiction in ejectment cases, ensuring a more efficient resolution of possessory disputes while still allowing for a separate, more comprehensive determination of ownership in the appropriate forum. Parties involved in similar land disputes must therefore navigate both judicial and administrative avenues to fully protect their rights.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Romualdo C. Perez, vs. Apolonio Cruz, G.R No. 142503, June 20, 2003