Asis v. Guevarra

Summary

This landmark case clarifies the jurisdiction of Metropolitan Trial Courts in ejectment proceedings when defendants raise ownership as defense. Consuelo Asis filed unlawful detainer against her brothers over apartment units, claiming exclusive ownership despite acknowledging co-ownership of the underlying land. The Supreme Court definitively ruled that under the 1997 Revised Rules of Civil Procedure, Section 16, Rule 70, MeTC has jurisdiction to resolve ownership issues provisionally for the sole purpose of determining possession. The Court distinguished this from pre-B.P. 129 jurisprudence and emphasized that such ownership determinations are merely provisional and do not bar subsequent actions for title. The decision establishes that unless the principal purpose is ownership recovery rather than possession restoration, MeTC retains jurisdiction over ejectment cases even when ownership is disputed, provided the ownership determination serves only to resolve the possession issue.