HEIRS OF DANILO ARRIENDA v. ROSARIO KALAW

FACTS:

The case involves a complaint for unlawful detainer filed by Danilo Arrienda against the respondent and three other individuals. Arrienda claimed ownership of the land and alleged that despite the warranty from the seller that the property is not tenanted, it was later discovered that the respondent and the other defendants were occupying a portion of it. Arrienda allowed them to continue occupying the premises subject to the condition that they would vacate upon prior notice. However, after informing them of his intention to use the land, the respondents failed and refused to vacate despite repeated demands. Arrienda filed the complaint seeking the respondents' eviction, payment for the use and occupation of the land, and damages.

The respondent denied the allegations and raised jurisdictional issues, claiming that the main issue in the case is the ownership of the disputed lot and that the Municipal Trial Court (MTC) has no jurisdiction over the matter. The MTC dismissed the complaint for lack of jurisdiction. Arrienda appealed to the Regional Trial Court (RTC), which ruled in favor of Arrienda, ordering the eviction of the respondents and payment of damages. However, the respondent filed a petition for review with the Court of Appeals (CA).

ISSUES:

  1. Whether or not the MTC has jurisdiction over the unlawful detainer case.

  2. Whether or not the RTC correctly ruled in favor of the petitioner and ordered the respondents to vacate the subject land.

RULING:

  1. The MTC does not lose jurisdiction over an unlawful detainer case simply because the defendant claims ownership of the property. The MTC can properly determine possession even if the question of ownership is raised. The MTC should not dismiss the case unless it is clear that the issue of ownership needs to be resolved before the issue of possession can be properly determined.

  2. The RTC correctly ruled in favor of the petitioner and ordered the respondents to vacate the subject land. Since the petitioner was able to establish his ownership of the property, he is entitled to possession under the law.

PRINCIPLES:

  • The MTC has jurisdiction over unlawful detainer cases and does not lose jurisdiction even if the defendant claims ownership of the property.

  • Ownership of a property entitles the owner to possess the property.