The Supreme Court in Heirs of Basilisa Hernandez v. Bernardo Vergara, Jr., ruled that Metropolitan Trial Courts (MeTC) retain jurisdiction over ejectment cases even when the defendant raises ownership claims that intertwine with the issue of possession. This decision reinforces that ejectment cases focus primarily on who has the right to physical possession, and the MeTC’s judgment on ownership is provisional, solely to determine possession. The ruling prevents defendants from using ownership claims to delay or obstruct rightful eviction.

Tolerance Ends: Can a Donee’s Claim of Ownership Block an Ejectment Suit?

The case began when the heirs of Basilisa Hernandez sought to evict Bernardo Vergara, Jr. from a property in Manila. Basilisa, during her lifetime, allowed Bernardo and his family to live on her property without requiring rent, expecting only that he would maintain the place. After Basilisa’s death, her heirs demanded that Bernardo vacate the property. Bernardo refused, asserting that Basilisa had donated the property to him when he was a child. This claim of donation became the crux of the legal battle, leading to conflicting decisions in the lower courts.

The MeTC initially sided with the heirs, ordering Bernardo to vacate the property, pay attorney’s fees, and cover the costs of the suit. The court emphasized that Basilisa’s heirs, upon her death, had the right to demand the property back, and Bernardo’s continued possession was therefore unlawful. The Regional Trial Court (RTC) affirmed the MeTC’s decision, maintaining that the central issue in ejectment cases is physical possession, regardless of ownership claims. However, the Court of Appeals (CA) reversed these decisions, arguing that the ownership issue was inseparable from possession and that the MeTC was an improper venue to resolve such a dispute. This divergence set the stage for the Supreme Court to clarify the jurisdictional boundaries in ejectment cases involving ownership claims.

The Supreme Court overturned the CA’s decision, reinstating the rulings of the MeTC and RTC. The Court emphasized that the primary issue in ejectment cases is physical possession, independent of any ownership claims. It reiterated the established doctrine that MeTCs have jurisdiction over ejectment cases, even if ownership questions arise. Section 33 of Batas Pambansa Blg. 129, as amended, explicitly grants Metropolitan Trial Courts exclusive original jurisdiction over cases of forcible entry and unlawful detainer, and further provides, “That when, in such cases, the defendant raises the question of ownership in his pleadings and the question of possession cannot be resolved without deciding the question of ownership, the issue of ownership shall be resolved only to determine the issue of possession.”

The Supreme Court cited the case of Garcia vs. Zosa, Jr., clarifying that raising the issue of ownership does not divest the MTC of its jurisdiction. The Court also referred to Section 18, Rule 70 of the 1997 Rules of Civil Procedure, as amended, to further strengthen its assertion:

“SEC. 18. Judgment conclusive only on possession, not conclusive in actions involving title or ownership. – The judgment rendered in an action for forcible entry or detainer shall be conclusive with respect to the possession only and shall in no wise bind the title or affect the ownership of the land or building. Such judgment shall not bar an action between the same parties respecting title to the land or building.”

This provision explicitly states that judgments in ejectment cases are conclusive only regarding possession and do not affect ownership rights. The Supreme Court stressed that the MeTC’s judgment on ownership is provisional and solely to determine the right to possess the property.

The Court emphasized that the heirs’ complaint sought to recover possession of the property inherited from Basilisa, from Bernardo who held it by mere tolerance. It noted that there was no intention to recover ownership but only to regain physical possession. This underscored the CA’s misinterpretation of the action as an accion reinvindicatoria, which is a lawsuit filed to recover ownership of real property.

FAQs

What was the central legal issue in this case?	The central issue was whether the Metropolitan Trial Court (MeTC) loses jurisdiction over an ejectment case when the defendant claims ownership of the property, thus intertwining the issues of possession and ownership.
What is an ejectment case?	An ejectment case is a legal action to remove a person from property, focusing on who has the right to physical possession. There are two common types of ejectment suits: unlawful detainer and forcible entry.
What is ‘possession by tolerance’ in property law?	Possession by tolerance occurs when a property owner allows another person to occupy their property without any contract or payment of rent. This possession can be terminated at any time by the owner, and the occupant is expected to vacate the property upon demand.
What is an accion reinvindicatoria?	An accion reinvindicatoria is a legal action filed to recover ownership of real property. It requires the plaintiff to prove not only their right to possess but also their ownership of the property.
How does this case affect property owners?	This case clarifies that property owners can pursue ejectment actions in the MeTC without being hindered by the occupant’s ownership claims, ensuring a faster resolution. This protection is crucial for landlords needing to regain possession.
What should a property owner do when facing similar situations?	Property owners should seek legal advice to understand their rights and properly file an ejectment case. It is vital to follow the correct legal procedures to avoid delays or complications in regaining possession of the property.
Does this ruling mean ownership disputes are irrelevant in ejectment cases?	No, ownership disputes can be considered, but only to determine the issue of possession, not to decide on the actual ownership of the property. The MeTC’s decision on ownership is provisional and doesn’t prevent a separate action to establish ownership definitively.
Where can an accion reinvindicatoria be filed?	The accion reinvindicatoria should be brought in the proper court, depending upon the value of the subject property, under the provisions of Batas Pambansa Blg. 129.

In conclusion, the Supreme Court’s decision in Heirs of Basilisa Hernandez v. Bernardo Vergara, Jr., reaffirms the jurisdiction of Metropolitan Trial Courts over ejectment cases, even when ownership issues are raised. This ruling reinforces that the central issue in such cases is physical possession and that the MeTC’s judgment on ownership is only provisional.

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: HEIRS OF BASILISA HERNANDEZ VS. BERNARDO VERGARA, JR., G.R. NO. 166975, September 15, 2006