In Ejectment, Courts Cannot Decide Issues Beyond the Pleadings

Why this case matters

A complaint for ejectment is a summary action meant to settle only one thing: who has the better right to possess a specific piece of property. When courts begin awarding possession or declaring ownership over parcels not named in the complaint, they cross a jurisdictional line. In Spouses Sioson v. Heirs of Federico Avanceña (G.R. No. 161387, March 13, 2009, 600 Phil. 247), the Supreme Court reversed the appellate rulings precisely because the lower courts decided an issue that the parties never pleaded.

The case

Respondents, heirs of Federico Avanceña, filed an ejectment complaint against petitioners before the Municipal Trial Court in Cities of Iloilo City. Respondents alleged that petitioners built cottages on their lot, Lot No. 934-B-4, covered by TCT No. T-111572. Respondents claimed they merely tolerated the occupation but that a demand to vacate was ignored. The complaint sought possession of Lot No. 934-B-4 only, plus damages.

Petitioners denied any encroachment. One pair of spouses claimed their cottage stood entirely on the adjoining Lot No. 934-B-7, a road-widening lot; the other pair said their cottage was across Molo-Arevalo Boulevard. During pre-trial, the parties limited the issues to: (1) whether petitioners had cottages on Lot No. 934-B-4, and (2) who was entitled to damages.

The MTCC dismissed the complaint, finding that petitioners’ cottages did not stand on Lot No. 934-B-4. On appeal, the Regional Trial Court reversed. It declared that the cottages encroached on parts of both Lot Nos. 934-B-4 and 934-B-7. It then went further, ruling that respondents and their co-heirs were owners pro-indiviso of Lot No. 934-B-7, and ordered petitioners to vacate it. The Court of Appeals affirmed.

The issue

The Supreme Court addressed two questions: whether the RTC, in its appellate jurisdiction, could decide an issue not raised in the pleadings or beyond the theory of the case; and whether it could reverse the MTCC’s factual findings despite the evidence.

The ruling

The Supreme Court sided with petitioners. The Court held that courts 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. When a court renders a decision on matters the parties never presented, that judgment is not merely irregular—it is extra-judicial and invalid (Salvante v. Cruz, 88 Phil. 236 [1951]; see also Liga v. Allegro Resources Corp., G.R. No. 175554, December 23, 2008).

In ejectment cases, the only issue is who is entitled to physical or material possession of the disputed property (Section 1, Rule 70, Rules of Court). Here, the complaint clearly named only Lot No. 934-B-4. The answer to the counterclaim reaffirmed that the subject was Lot No. 934-B-4. The preliminary conference order likewise limited the controversy to whether petitioners had cottages on Lot No. 934-B-4. Neither the pleadings nor the pre-trial order placed Lot No. 934-B-7 in issue.

By ruling on possession and ownership of Lot No. 934-B-7, the RTC and the Court of Appeals went beyond the case. The Supreme Court stressed that a judgment outside the issues violates fair play because the parties were not heard on that matter.

The factual error

The Court also corrected the factual findings. The RTC relied on the report and sketch plan of respondents’ geodetic engineer, but these documents were inconsistent with each other and with the title itself. The sketch plan did not show where Lot No. 934-B-7 was situated and contradicted the engineer’s own report. Meanwhile, petitioners’ engineer’s report and sketch plan were consistent with TCT No. T-111572, which stated