WILMON AUTO SUPPLY CORPORATION, ILOILO MULTI PARTS SUPPLY CORP., VIRGILIO ANG, SOUTHERN SALES CORP. and CHANG LIANG, JR., vs. HON. COURT OF APPEALS and STAR GROUP RESOURCES AND DEVELOPMENT, INC..
- G.R. Number: G.R. No. 97637
- Promulgated: 1992-04-10
- Ponente: Narvasa, J.
Doctrine
Even when ownership is raised in forcible entry and unlawful detainer cases, Metropolitan, Municipal and Municipal Trial Courts have competence to resolve ownership questions only insofar as necessary to determine possession.
The overwhelming weight of authority is contrary to the notion that RTC actions asserting rights of preemption automatically suspend or abate MTC unlawful detainer proceedings.
Facts
Star Group filed unlawful detainer actions in the Municipal Trial Court against lessees for holding over after lease expiration; some cases were ordered tried under summary procedure while others were not.
The lessees filed actions in the Regional Trial Court claiming a right of preemption (prior purchase) and sought judicial enforcement, prompting the question whether the MTC suits should be suspended or abated.
Petitioners moved for reconsideration and dismissal or abeyance of the ejectment suits; appeals were taken to this Court raising principally whether the MTCs had jurisdiction and whether proceedings should be suspended pending RTC adjudication.
Issues
Whether an unlawful detainer action in the Municipal Trial Court should be abated or suspended by a Regional Trial Court action where the defendant claims a right of preemption to the premises.
Whether the Municipal Trial Court has jurisdiction over actions that are real in nature and involve interpretation of lease contracts over immovables.
Whether the proceedings in the Municipal Trial Court for ejectment of lessees should be suspended until adjudication of RTC cases involving sale, ownership and physical possession of the property.
Ruling
The Court affirmed the Court of Appeals and dismissed the petitions, holding that unlawful detainer suits in MTCs are not abated by RTC actions on preemption and that MTCs have competence to resolve possession even if ownership issues arise.
Keywords
G.R. No. 97637, unlawful detainer, right of preemption, lease contracts, Deed of Absolute Sale, leasehold rights, Civil Case No. 18931, null and void ab initio, right of redemption, litis pendentia, lack of jurisdiction, Rules of Summary Procedure, certiorari, restraining order, expiration of the lease, vendee, lessor-co-owners, registered land, moral damages, branch