The Supreme Court has denied a petition filed by Spouses Virgilio Guasis and Ma. Estrelita Guasis, affirming lower court rulings that ordered them to vacate a Pasig City property and pay the costs of suit in an unlawful detainer case filed by Spouses Manuel Millan and Edna DC Millan.
In a decision under G.R. No. 268123, the Court held that the Metropolitan Trial Court (MeTC) properly limited its ruling to the issue of possession and did not err in refusing to determine ownership of the property.
The Case
On December 18, 2018, Spouses Millan, represented by their children Pia Rita Millan and Emmanuel Patrick Millan, filed a complaint for unlawful detainer against Spouses Guasis before the MeTC. Spouses Millan alleged that in 2008 they purchased a parcel of land at No. 098 Sta. Maria Compound, Phase IV, Santolan, Pasig City through a Deed of Absolute Sale.
As a result of the sale, Spouses Millan were issued Transfer Certificate Title (TCT) No. PT-141439. Despite this, Spouses Guasis refused to vacate the property. Spouses Millan asserted they had merely tolerated the continued occupancy of Spouses Guasis, made multiple verbal demands to vacate, and on October 11, 2019 sent a formal demand letter, which Spouses Guasis disregarded.
In their Answer with Counterclaim, Spouses Guasis argued the complaint lacked a cause of action and contended that the Deed of Absolute Sale was a fictitious contract that lacked valid consideration. They claimed Spouses Millan paid only PHP 750,000.00, leaving an outstanding balance of PHP 7,710,000.00, and maintained the sale was void for absence of consideration. They also said they remained in possession and continued paying real property taxes.
The Issue
The central questions were whether failure to undergo barangay conciliation defeated the case, and whether the MeTC could rule on ownership of the property in a summary unlawful detainer suit.
The Ruling
The Court denied the petition. Its disposition reads: "ACCORDINGLY, the Petition for Review on Certiorari is DENIED. The Decision, dated November 22, 2022, and the Resolution, dated July 5, 2023, of the Court of Appeals in CA-G.R. SP No. 171105 are AFFIRMED."
Earlier, the MeTC had ruled in favor of Spouses Millan, ordering Spouses Guasis to vacate the property covered by TCT No. PT-141439, deliver peaceful possession, and pay costs of suit in the amount of PHP 2,215.00, while denying the counterclaim. The Regional Trial Court (RTC) dismissed the appeal and affirmed the MeTC. The Court of Appeals (CA) dismissed the Rule 42 petition for lack of merit.
By the Numbers
- G.R. No. 268123
- Deed of Absolute Sale executed in 2008
- Complaint filed December 18, 2018
- Formal demand letter sent October 11, 2019
- MeTC Decision dated February 5, 2021
- RTC Decision dated October 11, 2021
- CA Decision dated November 22, 2022; Resolution dated July 5, 2023
- Amount paid: PHP 750,000.00; total purchase price PHP 8,460,000.00; outstanding balance PHP 7,710,000.00
- Costs of suit: PHP 2,215.00
- TCT No. PT-141439
The Court's Reasoning
The Court explained that, as a general rule, a party must raise grounds for dismissal at the earliest opportunity, such as in a motion to dismiss or in their answer, otherwise these grounds are considered waived. It emphasized that failure to comply with the condition precedent does not affect jurisdiction. Citing Aquino v. Aure and Banares II v. Balising, the Court reiterated that the barangay conciliation process is not a jurisdictional requirement and may be waived if not timely raised.
Because Spouses Guasis did not raise non-compliance with the barangay conciliation requirement in their answer, a motion to dismiss, or during pre-trial, but only belatedly in their Position Paper, the issue was deemed waived.
On ownership, the Court held that in ejectment cases the MeTC has limited jurisdiction, strictly confined to determining who has the superior right to physical or material possession. While the court may provisionally decide ownership when raised, this does not empower it to make a definitive ruling on ownership or annul a certificate of title. Under the Torrens system, a certificate of title is conclusive and indefeasible unless annulled by a court of competent jurisdiction in a direct proceeding, and matters of ownership, annulment of title, or reconveyance fall within the exclusive jurisdiction of the RTC.
The Court acknowledged that, in light of the alleged unpaid balance, the transaction may be characterized as a contract to sell, but ruled that such an issue cannot be definitively resolved in a summary proceeding and is properly the subject of a separate action before the RTC. It noted that if Spouses Guasis wish to dispute ownership, they must file the appropriate action before the RTC.
Source: Supreme Court decision in G.R. No. 268123.
This report summarizes a public Supreme Court decision and is not legal advice.