Jose Ching vs Antonio Malaya

G.R. No. L-56449 – 153 SCRA 412 – Civil Law – Land Titles and Deeds – Essence of Registration in General

Jose Ching et al and the Spouses Cesar and Araceli Alvarado were disputing possession over a parcel of land. Ching averred that the Alvarados encroached upon their land. An ejectment case was filed and the MTC (Municipal Trial Court) took cognizance thereof. The MTC ruled in favor of Ching. Alvarado appealed before the RTC (Regional Trial Court) and Judge Antonio Malaya held that the MTC has no jurisdiction over the case because the issue between the two parties was not a mere possession case. The two parties actually adduced evidence of ownership: i.e. Deed of Sale presented by Ching and inheritance claims by Alvarado. Judge Malaya ruled that MTCs have no jurisdiction over ownership cases.

ISSUE: Who is the rightful possessor?

HELD: MTCs do not have jurisdiction over ownership cases. But the SC (Supreme Court) held that this particular case is not an ownership case. The mere circumstance that proof of title, or evidence of ownership, had been introduced during the trial before the Municipal Court would not deprive said court of jurisdiction to rule on the question of who had the prior physical possession. The parties just showed evidence of ownership so as to prove possession – this will not divest the MTC of its jurisdiction.

On the other hand, the land is registered under Ching’s name in the Registry of Deeds in Laguna. The land was actually sold to him by Alvarado’s father in 1978. No protest was ever filed against the Deed of Sale since 1978. Alvarado only filed an annulment case (which is a separate case) when the ejectment case was filed. With a strong evidence to back Ching’s claim, the MTC’s decision was reinstated by the SC.

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