OBLEA V. CA|ESTEBAN, 244 SCRA 101
FACTS:
The lot in issue was originally registered in the names of Manuel Melencio, Pura Melencio, Wilfredo Wico and Mariabelle Wico. But was subsequently re-registered in the name of Ramon Melencio (son of deceased Manuel Melencio), Pura Melencio and the Wicos via a deed of sale.
On 6 June 1958 subject lot was bought by private respondent Juan S. Esteban from Mauricio Ramos who claimed to have acquired the property from Ursula Melencio, the alleged administratrix of the estate of Manuel and Pura Melencio.
Meanwhile, petitioner Romeo V. Oblea leased a building located on the subject lot from a certain Marius Esteban, an alleged son of private respondent Juan S. Esteban. Oblea eventually bought from Marius the lot on which the building stood. As a consequence, on 4 July 1991 Juan Esteban filed an ejectment suit against petitioner Oblea.
MTC decided for Juan Esteban and ordered Oblea to vacate and pay arrears. On appeal, RTC affirmed MTC.
On 3 June 1993, the registered owners (Ramon Melencio, Pura Melencio and Wilfredo Wico and Mariabelle Wico) sold the disputed lot to petitioner Oblea. Afterwards, Oblea together with the registered owners filed before the RTC an action for quieting of title against Juan Esteban. They contended that the deeds of sale executed by Mauricio Ramos in favor of Juan Esteban and by Ursula Melencio in favor of Mauricio Ramos were a nullity.
Meanwhile, the ejectment case was appealed thrice to the CA but all were denied.
In the appeal to the SC, Oblea asserts that the subsequent sale to him by the registered owners is a supervening event that gave him a better right of possession and ownership. Hence the judgment of eviction can no longer be enforced.
ISSUE:
Whether or not a subsequent action to quiet title in the RTC divests the MTC of its jurisdiction over an ejectment case?
HELD:
No.The sole issue in an action for unlawful detainer is physical or material possession, i.e., possession de facto and not possession de jure. The pendency of an action for quieting of title before the RTC does not divest the MTC of its jurisdiction to proceed with the ejectment case over the same property. The subsequent acquisition of ownership by petitioners is not a supervening event that will bar the execution of the judgment in said unlawful detainer case, the fact remaining that when judgment was rendered by the MTC in the ejectment case, petitioner Oblea was a mere possessor of the subject lot.
Similarly, the fact that petitioners instituted a separate action for quieting of title is not a valid reason for defeating the execution of the summary remedy of ejectment. On the contrary., it bolsters the conclusion that the eviction case did not deal with the issue of ownership which was precisely the subject matter of the action for quieting of title before the RTC. With the finality of the decision in the ejectment case, execution in favor of the prevailing party has become a matter of right; its implementation mandatory. It cannot be avoided.
