CASE DIGEST : Eufrocina Rivera v. Rolando G. Velasco G.R. No. 242837, October 5, 2022 GAERLAN

FACTS

Eufrocina Rivera filed a complaint for forcible entry under Rule 70 of the Rules of Court against Rolando Velasco before the Municipal Trial Court (MTC). Rivera alleged that she was the registered owner of three parcels of land in General Tinio, Nueva Ecija, covered by Original Certificates of Title (OCTs), and that she and her predecessors had been in prior physical possession of the properties since 1992. She discovered that Velasco had entered and occupied a portion of the land by strategy and stealth, constructed a house thereon without her consent, and refused to vacate despite demand. The MTC ruled in Rivera's favor, finding that all the elements of forcible entry were established, and the RTC affirmed the decision.

On appeal, however, the Court of Appeals (CA) reversed the RTC and dismissed the complaint. The CA held that the controversy primarily involved ownership because Velasco questioned the validity of Rivera's Torrens titles and had pending actions before the DENR and the RTC seeking reconveyance. It ruled that the dispute should instead be resolved in an accion reivindicatoria rather than an ejectment case. Rivera elevated the matter to the Supreme Court through a Petition for Review on Certiorari under Rule 45, arguing that the CA improperly disregarded the nature of an ejectment suit and allowed an impermissible collateral attack on her Torrens titles.

ISSUE

Whether the Court of Appeals erred in dismissing Rivera's complaint for forcible entry under Rule 70 of the Rules of Court on the ground that the case involved an issue of ownership requiring an accion reivindicatoria, despite the complaint sufficiently alleging prior physical possession and dispossession through strategy and stealth.

Whether Velasco could validly challenge Rivera's Torrens titles in an ejectment case, considering Section 48 of Presidential Decree No. 1529 (Property Registration Decree), which provides that a certificate of title cannot be altered, modified, or cancelled except in a direct proceeding, and that a Torrens title is immune from collateral attack.

HELD

The Supreme Court granted the petition, reversed the Court of Appeals, and reinstated the decisions of the MTC and RTC. It held that Rivera's complaint clearly stated a valid cause of action for forcible entry under Rule 70, as it sufficiently alleged and proved the essential elements of the action: (1) prior physical possession of the property, and (2) deprivation of such possession through force, intimidation, threat, strategy, or stealth. The Court emphasized that an ejectment case is intended solely to determine material or physical possession (possession de facto) and not ownership. Even when ownership is raised as a defense, the court may resolve it only provisionally insofar as necessary to determine possession, without conclusively adjudicating title.

The Court further ruled that the CA erred in allowing Velasco's challenge to Rivera's Torrens titles. Under Section 48 of Presidential Decree No. 1529, a Torrens title is indefeasible and may be attacked only through a direct proceeding, not collaterally in an ejectment suit. Since Rivera possessed valid certificates of title, she was presumed entitled to possession of the property. The Court reiterated that ownership disputes cannot defeat or delay an action for forcible entry, as allowing otherwise would undermine the summary nature of ejectment proceedings. Accordingly, the Court ordered Velasco to vacate the property and reinstated the award of rentals, attorney's fees, costs of suit, and legal interest of 6% per annum, consistent with Nacar v. Gallery Frames, reckoned from the finality of the decision until full satisfaction