SPOUSES ADRIANO AND NORMA SIOSON and SPOUSES ARNIEL AND EDITH SIOSON, PETITIONERS, VS.

Sioson versus Sioson

The Case

This is a petition for review brought by the Sioson spouses against the heirs of Federico Avanceña, arising from a complaint for ejectment over a parcel of land in Iloilo City. The respondents claim that the petitioners built their cottages on the respondents' lot without any lease agreement, merely by tolerance, and refused to leave despite demand. The petitioners insist their cottages stand elsewhere. The case matters because it draws a hard line around the jurisdiction of courts in ejectment actions: a court may decide only the question of physical possession of the property actually pleaded, and a judgment that reaches beyond the issues framed by the parties is void for being extra-judicial. It also shows the Supreme Court correcting a factual finding of the appellate courts where the evidence plainly did not support it.

Procedural History

The heirs of Federico Avanceña filed a complaint for ejectment before the Municipal Trial Court in Cities of Iloilo City, Branch 2. After an ocular inspection and a relocation survey, the municipal trial court rendered judgment in favor of the petitioners, dismissing the complaint and likewise dismissing the counterclaim for lack of merit.

The respondents appealed to the Regional Trial Court of Iloilo City, Branch 33. The regional trial court reversed the municipal trial court, ordering the petitioners to vacate portions of two lots, to pay monthly rentals, attorney's fees, and costs of litigation. The petitioners then appealed to the Court of Appeals, which affirmed the regional trial court in a decision dated 26 June 2003. The Court of Appeals denied the petitioners' motion for reconsideration on 4 December 2003.

The petitioners elevated the matter to the Supreme Court through a petition for review under Rule 45 of the Rules of Court. The Supreme Court granted the petition, set aside the Court of Appeals, and reinstated the decision of the municipal trial court.

Facts

On 4 June 1996, the heirs of Federico Avanceña filed a complaint for ejectment against spouses Adriano and Norma Sioson and spouses Arniel and Edith Sioson. The respondents alleged that the petitioners constructed their cottages on a portion of their lot, identified as Lot No. 934-B-4, covered by Transfer Certificate of Title No. T-111572. They maintained that there was no lease agreement and that they merely tolerated the petitioners' occupation. A demand letter dated 3 May 1996 to vacate went unheeded, prompting the complaint, in which they also asked for rent, attorney's fees, costs, and moral and exemplary damages.

In their answer with counterclaim, the petitioners denied that their cottages stood on Lot No. 934-B-4. Spouses Adriano and Norma Sioson claimed their cottage stood entirely on Lot No. 934-B-7, a road-widening lot bounding Lot No. 934-B-4 on the south. Spouses Arniel and Edith Sioson claimed their cottage stood across Molo-Arevalo Boulevard, on neither lot. The respondents admitted that Lot No. 934-B-7 was reserved for a proposed road widening, but asserted that the project had not been implemented and no expropriation proceedings had been initiated by the City of Iloilo.

At the preliminary conference, the parties agreed to limit the issues to whether the petitioners had cottages standing on Lot No. 934-B-4 and who among them were entitled to damages. The municipal trial court, relying on an ocular inspection and a relocation survey, found that the cottage of spouses Adriano and Norma Sioson stood entirely on Lot No. 934-B-7 with only its walls on the boundary of Lot No. 934-B-4, and that the cottage of spouses Arniel and Edith Sioson stood on neither lot. The regional trial court reversed, crediting the report and sketch plan of the respondents' geodetic engineer, and declared the petitioners liable to vacate portions of both lots and to pay rentals and costs. The Court of Appeals affirmed.

Issues

• Whether or not the regional trial court, in the exercise of its appellate jurisdiction, could reverse the municipal trial court by deciding an issue not raised in the pleadings or beyond the theory of the case before the lower court.
• Whether or not the regional trial court could, on appeal, reverse the factual findings of the municipal trial court which were clearly supported by the evidence.

Applicable Provisions

Section 1 of Rule 70 of the Rules of Court defines the action for forcible entry and unlawful detainer and fixes its single subject matter, the physical or material possession of the property in dispute:

Section 1. Who may institute proceedings, and when. Subject to the provisions of the next succeeding section, a person deprived of the possession of any land or building by force, intimidation, threat, strategy, or stealth, or a lessor, vendor, vendee, or other person against whom the possession of any land or building is unlawfully withheld after the expiration or termination of the right to hold possession, by virtue of any contract, express or implied, or the legal representatives or assigns of any such lessor, vendor, vendee, or other person, may, at any time within one year after such unlawful deprivation or withholding of possession, bring an action in the proper Municipal Trial Court against the person or persons unlawfully withholding or depriving of possession, or any person or persons claiming under them, for the restitution of such possession, together with damages and costs.

This provision confines the ejectment action to the recovery of possession of the land actually described in the complaint, which in this case was Lot No. 934-B-4 alone.

Ruling

On the first issue, the Court ruled in favor of the petitioners. Courts of justice have no jurisdiction or power to decide a question not in issue. A judgment must conform to, and be supported by, both the pleadings and the evidence, and must accord with the theory of the action on which the pleadings were framed and the case was tried. A judgment that goes outside the issues and purports to adjudicate something on which the court did not hear the parties is not only irregular but also extra-judicial and invalid, a rule resting on the fundamental tenets of fair play. The Court held that in an ejectment case the only issue for resolution is the question of who is entitled to the physical or material possession of the property in dispute. Here, the complaint clearly stated that its subject matter was Lot No. 934-B-4, the answer to counterclaim reaffirmed this, and the preliminary conference order limited the issue to whether the petitioners had cottages on that lot. By ruling on the possession and ownership of Lot No. 934-B-7, the regional trial court and the Court of Appeals went beyond the issue of the case.

On the second issue, the Court again ruled for the petitioners. While generally only questions of law are appealable under Rule 45, the Court may review and reverse factual findings where those of the trial court conflict with those of the appellate court and the appellate court manifestly overlooked relevant facts that would justify a different conclusion. Examining the records, the Court found the regional trial court's factual findings unsupported by the evidence. The report and sketch plan of the respondents' geodetic engineer were inconsistent and contradictory: the sketch plan, which did not even indicate where Lot No. 934-B-7 was located, showed the entire cottages inside Lot No. 934-B-4, contradicting the report that they stood on both lots. That sketch plan was also inconsistent with the respondents' own title, which stated that Lot No. 934-B-4's southern boundary ran by Lot No. 934-B-7, and with the respondents' subdivision plan. The report and sketch plan of the petitioners' geodetic engineer, by contrast, were complementary and consistent even with the respondents' other evidence. The Court therefore reversed the appellate factual finding and affirmed the municipal trial court's finding that the petitioners' cottages stand on Lot No. 934-B-7 and do not encroach on Lot No. 934-B-4.

Doctrine

• A court has no jurisdiction to decide a question not in issue. A judgment must conform to, and be supported by, both the pleadings and the evidence, and must follow the theory of the action on which the pleadings were framed and the case was tried.
• A judgment that goes outside the issues and adjudicates something on which the court did not hear the parties is not only irregular but also extra-judicial and invalid, because it violates the fundamental tenets of fair play.
• In an ejectment case under Section 1 of Rule 70, the only issue is who is entitled to the physical or material possession of the property in dispute, and the court may rule only on the lot actually pleaded and litigated.
• As an exception to the rule that only questions of law are appealable under Rule 45, the Supreme Court may review and reverse factual findings where the findings of the trial court and the appellate court conflict and the appellate court manifestly overlooked relevant facts that, if properly considered, would justify a different conclusion.

Disposition

The petitioners won. The Supreme Court set aside the decision and resolution of the Court of Appeals and reinstated the decision of the Municipal Trial Court in Cities of Iloilo City, Branch 2, dismissing the complaint for ejectment.

Remember This

Memorize this line: a judgment that goes outside the issues and adjudicates something on which the court did not hear the parties is not only irregular but also extra-judicial and invalid. Examiners use this case to test the jurisdictional limits of ejectment courts and the recognized exception allowing the Supreme Court to review conflicting factual findings under Rule 45.