Tiña vs. Sta. Clara Estate, Inc.

A ruling on ownership made in an ejectment case is provisional and does not bar a subsequent independent action for cancellation of title or reconveyance, even between the same parties and involving identical property, because ejectment courts lack jurisdiction to definitively resolve questions of title or the validity of certificates of title.

The dispute involves a 231-square-meter parcel situated along Creek I (Ogumod Creek) in Bacolod City. Petitioner claimed ownership through open, continuous, adverse possession spanning over 55 years and secured administrative approval of a Miscellaneous Sales Application from the Department of Environment and Natural Resources. Respondent asserted ownership under Transfer Certificate of Title No. T-28629 registered in 1965, contending that Creek I is a man-made drainage dam constructed within its private subdivision and not a natural waterway subject to public dominion. The conflicting claims spawned parallel litigation: an ejectment action filed by respondent and a cancellation of title action filed by petitioner.

• The Contested Property: The subject is a 231-square-meter lot along Creek I (Ogumod Creek) in Bacolod City. Petitioner alleged that she and her husband occupied the property for over 55 years openly, publicly, adversely, and continuously in the concept of an owner. As proof, petitioner presented a January 10, 1990, indorsement by Engr. Jose F. Falsis, Jr., confirming 45 years of occupancy since 1990, and an October 23, 1997, Certification from the Barangay Council of Mandalagan. Petitioner filed a Miscellaneous Sales Application on July 22, 1986, which the Department of Environment and Natural Resources approved on December 10, 1997, without opposition from the City Engineer, Department of Public Works and Highways, or City Mayor.

• Respondent’s Title and Opposition: Respondent asserted ownership based on Transfer Certificate of Title No. T-28629 entered in the Registry of Deeds of Bacolod City on June 11, 1965, derived from TCT Nos. T-14900 to T-14902. Respondent claimed Creek I is a man-made creek constructed as a drainage dam within the Sta. Clara Subdivision. The City Assessor of Bacolod issued a letter to petitioner stating that the property could not be appraised under her Patent Application because it falls within respondent's property covered by TCT No. T-28629, comprising 4,419 square meters.

• Parallel Proceedings: On March 3, 1999, respondent instituted an ejectment suit before the MTCC. Petitioner countered on April 28, 2000, by filing a complaint for cancellation of title with damages before the RTC, docketed as Civil Case No. 00-11133, alleging that Creek I is property of public dominion and therefore incapable of private registration. Respondent maintained the creek was artificially constructed.

• Ejectment Resolution: The MTCC ruled for respondent on May 9, 2002, finding it the registered owner who constructed the man-made creek, and ordered petitioner to vacate and remove her structures. The RTC affirmed on July 23, 2003, and the Court of Appeals upheld the judgment. The Supreme Court affirmed the ejectment on September 21, 2015, denied reconsideration on April 18, 2016, and issued Entry of Judgment.

• Motion to Dismiss in Cancellation Action: During the pendency of Civil Case No. 00-11133, respondent filed a Manifestation with Motion to Dismiss asserting that the principal issue—whether Creek I is man-made or a public creek—had been conclusively resolved in the ejectment case. Petitioner opposed, contending that the ejectment issue was confined to possession and that substantial evidence showed Creek I is natural.

• Trial Court Dismissal: The RTC dismissed Civil Case No. 00-11133 via Resolution dated March 30, 2017, relying on the Supreme Court's pronouncement in the ejectment case that Creek I belongs to respondent. The RTC denied petitioner's Earnest Motion for Reconsideration on May 11, 2018.

• Premature Termination: Petitioner argued that the RTC erred in dismissing the cancellation of title action based solely on the ejectment judgment, contrary to established jurisprudence that determinations of ownership in ejectment proceedings are merely ancillary to resolving possession and do not bind subsequent title disputes.

• Public Dominion: Petitioner maintained that Creek I constitutes property of the public dominion, rendering respondent's title void ab initio and justifying cancellation.

• Res Judicata and Finality: Respondent countered that the issue of whether Creek I is man-made and belongs to respondent had already attained finality in the ejectment case, precluding relitigation in the cancellation suit.

• Lack of Standing: Respondent argued that petitioner is not the proper party to prosecute the complaint because she asserts the property belongs to the State rather than to herself, thereby lacking the requisite interest to seek reconveyance or cancellation.

• Propriety of Dismissal Based on Prior Ejectment Judgment: Whether the RTC erred in dismissing the complaint for cancellation of title on the ground that the ejectment judgment had already resolved the issue of ownership.

• Binding Effect of Provisional Ownership Determination: Whether a determination of ownership made in an ejectment proceeding constitutes res judicata in a subsequent independent action directly attacking the validity of title.

• Propriety of Dismissal: The dismissal was erroneous. An ejectment court's resolution of ownership—permitted under Section 16, Rule 70 of the Rules of Court only when possession is intertwined with ownership—serves solely to determine who is entitled to physical possession and does not finally settle title disputes.

• Binding Effect: The adjudication of ownership in the ejectment case was provisional only and not a bar to Civil Case No. 00-11133. Questions regarding the validity of title require a separate action, as filed herein, to fully thresh out the parties' respective rights; consequently, the ejectment ruling on ownership should not have bound the trial court in the cancellation proceeding.

• Provisional Determination of Ownership in Ejectment: In ejectment cases, where the issue of ownership is inseparably linked to possession, the court may resolve ownership solely for the purpose of determining possession. Such adjudication is provisional, not final, and does not constitute res judicata in a subsequent action between the same parties involving title to the property.

• Question of Law vs. Question of Fact: A question of law arises when the doubt concerns the correct application of law to given facts without examination of probative value; a question of fact exists when the doubt concerns the truth or falsity of alleged facts requiring evaluation of evidence. The present petition involved a pure question of law regarding the effect of the prior ejectment judgment, justifying direct appeal under Rule 45.

• "the sole issue in ejectment cases is physical or material possession of the subject property, independent of any claim of ownership by the parties." — Articulates the limited scope of ejectment jurisdiction.

• "where the issue of ownership is inseparably linked to that of possession, adjudication of the issue on ownership is not final and binding, but merely for the purpose of resolving the issue of possession." — Establishes the provisional nature of ownership determinations under Section 16, Rule 70.

• "In an ejectment case, questions as to the validity of the title cannot be resolved definitively. A separate action to directly attack the validity of the title must be filed..." — Affirms the necessity of independent actions for title cancellation despite prior ejectment rulings.

• Holy Trinity Realty Development Corporation v. Abacan, 709 Phil. 653 (2013) — Cited as controlling precedent establishing that the sole issue in ejectment is physical possession, independent of ownership claims.

• Santiago v. Northbay Knilling, G.R. No. 217296, October 11, 2017, 842 SCRA 502 — Followed for the principle that adjudication of ownership in ejectment is provisional only and not a bar to subsequent title actions.

• Quijano v. Amante, 745 Phil. 40 (2014) — Cited to reinforce the provisional character of ownership determinations made in ejectment proceedings.

• Far Eastern Surety and Insurance Co., Inc. v. People, 721 Phil. 760 (2013) — Cited for the distinction between questions of law and questions of fact in determining the propriety of Rule 45 appeals.

• Section 16, Rule 70, Rules of Court — Provides the exception allowing resolution of ownership issues in ejectment cases when intertwined with possession; limited to determining possession only.

• Rule 45, Section 4, Rules of Court — Basis for the directive dropping the Register of Deeds as a party-respondent in the direct appeal to the Supreme Court.

Perlas-Bernabe (Chairperson), A. Reyes, Jr., Inting, and Delos Santos, JJ.