In ejectment cases, Philippine courts maintain jurisdiction even when a defendant raises claims of ownership, as the core issue remains physical possession, not title. This means that a party cannot avoid an ejectment suit simply by asserting they own the property; the court will still determine who has the right to possess it. This ruling reinforces the principle that certificates of title provide strong evidence of ownership and can only be challenged in direct proceedings.

Possession vs. Ownership: Can an Ejectment Suit Decide Who Really Owns the Land?

The case of Diana Jeanne Lopez v. Spouses Edilberto and Eveline Pozon arose from a dispute over a property in Makati City. Tradex Development Corporation initially agreed to sell the property to the Pozons but later rescinded the agreement and sold it to J.H. Pajara Construction Corporation. The Pozons sued Tradex, leading to a court order compelling Tradex to transfer the property to them. However, Diana Jeanne Lopez, who was occupying the property, claimed ownership, leading the Pozons to file an ejectment suit against her. Lopez argued that she was the true owner and that the court lacked jurisdiction because the case involved conflicting ownership claims.

The Metropolitan Trial Court (MeTC) ruled in favor of the Pozons, asserting its jurisdiction over the ejectment case despite Lopez’s ownership claims. The MeTC emphasized that an ejectment case focuses on physical possession, not ownership. The Regional Trial Court (RTC) and the Court of Appeals (CA) upheld this decision. Lopez then appealed to the Supreme Court, reiterating her claim of ownership and challenging the lower courts’ jurisdiction.

The Supreme Court affirmed the lower courts’ decisions, underscoring that in ejectment cases, the issue is who has the right to physical possession. The Court referenced Section 47 of Act 497, the Land Registration Act, which provides that a Certificate of Title is conclusive proof of ownership. Additionally, Section 48 of Presidential Decree 1529 states that a certificate of title cannot be collaterally attacked. This means that the validity of a title can only be questioned in a direct proceeding specifically aimed at altering, modifying, or canceling it, not in an ejectment case.

The Court addressed Lopez’s argument that the Pozons should have included her in the original case against Tradex. The Court noted that Lopez had previously attempted to intervene in those proceedings but was denied. The Supreme Court emphasized that it is not a trier of facts and cannot rule on Lopez’s ownership claim, which was already being litigated in a separate action for quieting of title. The Court stated:

This Court is not a trier of facts nor can it take cognizance of facts alleged by Lopez that have yet to be proven in an appropriate proceeding, such as Civil Case No. 96-692 pending in the RTC of Makati City, Branch 60.

This ruling confirms that an ejectment case is the proper venue to determine the right to physical possession, irrespective of ownership claims. The Supreme Court underscored the importance of respecting the Torrens system, where a certificate of title provides strong evidence of ownership. This case clarifies that a defendant cannot simply claim ownership to oust the court of jurisdiction in an ejectment proceeding. The court maintains jurisdiction to determine who has the right to possess the property, based on the presented evidence. Furthermore, a certificate of title holds significant weight and can only be challenged through a direct proceeding.

Issue	Lopez’s Argument	Court’s Reasoning
Jurisdiction	The MeTC lacked jurisdiction because the case involved ownership, not just possession.	The MeTC has jurisdiction over ejectment cases, which focus on physical possession, not ownership.
Ownership	Lopez claimed to be the true owner of the property, not Tradex.	The Pozons held a Transfer Certificate of Title (TCT), which is conclusive proof of ownership under the Land Registration Act.
Indispensable Party	Lopez should have been included in the original case against Tradex.	Lopez had previously attempted to intervene in the original case but was denied.
Nature of Possession	Her occupancy was not merely tolerated by Tradex.	The lower courts found that Tradex initially allowed her to occupy the property, and this tolerance ended when the property was sold to the Pozons.

This decision aligns with established jurisprudence that aims to provide a swift resolution to possession disputes. It reinforces the principle that procedural technicalities and tangential claims should not unduly delay the resolution of ejectment cases. By upholding the lower courts’ rulings, the Supreme Court underscored the importance of adhering to the Torrens system and respecting the rights of registered owners. This helps in ensuring that property rights are protected and that disputes are resolved efficiently.

FAQs

What was the key issue in this case?	The central issue was whether the Metropolitan Trial Court (MeTC) had jurisdiction over an ejectment case when the defendant claimed ownership of the property. The Supreme Court affirmed that the MeTC did have jurisdiction, as ejectment cases focus on physical possession, not ownership.
What is an ejectment case?	An ejectment case is a legal action filed to recover the right to physical possession of a property from someone who is unlawfully occupying it. This type of case is designed for a speedy resolution to determine who has the immediate right to possess the property.
What is a Transfer Certificate of Title (TCT)?	A TCT is a document issued by the Registry of Deeds that serves as proof of ownership of a particular property. Under the Torrens system, a TCT is considered strong evidence of ownership and can only be challenged in a direct proceeding.
What does it mean to say a TCT cannot be collaterally attacked?	To say that a TCT cannot be collaterally attacked means its validity cannot be questioned in a proceeding that is not specifically aimed at challenging the title itself. A collateral attack would be an attempt to question the TCT in a different type of case, such as an ejectment case.
What is the significance of the Torrens system?	The Torrens system is a land registration system that aims to provide security and stability in land ownership. Under this system, a certificate of title is considered conclusive evidence of ownership, making land transactions more reliable.
What is an action for quieting of title?	An action for quieting of title is a legal proceeding filed to remove any cloud, doubt, or claim on a property’s title. This type of action is used to ensure that the title is clear and free from any encumbrances or adverse claims.
What was the basis for the Pozons’ claim to the property?	The Pozons based their claim on a Transfer Certificate of Title (TCT) issued in their name, which they obtained after a court order compelled Tradex to transfer the property to them. The TCT served as their primary evidence of ownership and right to possession.
Why was Diana Jeanne Lopez not included in the original case against Tradex?	Diana Jeanne Lopez was not initially included in the case against Tradex. The court noted that Lopez had previously attempted to intervene in those proceedings but was denied, and therefore, her non-inclusion in the original case was not a basis to dismiss the ejectment suit.

This case highlights the importance of understanding the distinction between possession and ownership in property disputes. While ownership is a significant factor, the right to physical possession is often the immediate issue in ejectment cases. This ruling reinforces the stability and reliability of the Torrens system in the Philippines, ensuring that property rights are respected and protected.

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: Diana Jeanne Lopez v. Spouses Edilberto and Eveline Pozon, G.R. No. 152745, March 17, 2004