Case Digest (G.R. No. 205490) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Filomena Domagas v. Vivian Layno Jensen, petitioner Domagas, the registered owner of an 827-square-meter parcel in Barangay Buenlag, Calasiao, Pangasinan (OCT No. P-30980), filed on February 19, 1999 a forcible entry complaint against respondent Jensen before the Municipal Trial Court (MTC) of Calasiao. She alleged that on January 9, 1999 Jensen, by means of force and stealth, encroached upon and fenced in a 68-square-meter portion of her land. Petitioner sought a preliminary mandatory injunction, an order to vacate, monthly rentals, actual, moral and exemplary damages, attorney’s fees, and costs. Because Jensen was in Oslo, Norway, the sheriff effected substituted service on April 5, 1999 by leaving summons and complaint with Jensen’s brother, Oscar Layno, at the latter’s house—though that dwelling was leased to another. On May 17, 1999 the MTC ordered Jensen to vacate the disputed area and pay P1,000 monthly rent, P20,000 actual damages, P15,000 attorney’s fees, P20,000 exe Case Digest (G.R. No. 205490) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Proceedings in the Municipal Trial Court (MTC)
- On February 19, 1999, petitioner Filomena Domagas filed a forcible entry complaint against respondent Vivian Layno Jensen before the MTC of Calasiao, Pangasinan, alleging ownership of an 827 m² parcel (OCT No. P-30980) and that, on January 9, 1999, respondent by force, strategy and stealth excavated 68 m² and erected a fence.
- Petitioner prayed for:
- Service of Process and MTC Decision
- Respondent was abroad; the Sheriff substituted service on her brother Oscar Layno at No. 572, Brgy. Buenlag, who signed for the summons.
- On May 17, 1999, the MTC ordered respondent to vacate the 68 m², pay ₱1,000/month rental, actual damages ₱20,000, attorney’s fees ₱15,000, exemplary damages ₱20,000, and costs.
- Annulment Petition in the Regional Trial Court (RTC)
- Respondent did not appeal; a writ of execution issued September 27, 1999.
- On August 16, 2000, respondent filed Civil Case No. 2000-0244-D in the RTC, seeking annulment of the MTC decision for lack of jurisdiction over her person and alleged lack of prior possession by petitioner.
- Documentary evidence included respondent’s passport (abroad since February 17, 1999), a 1997 lease of her house to Eduardo Gonzales, affidavits of respondent, Oscar Layno and Gonzales, petitioner’s deed of sale (1992), mortgage contract (February 9, 1999), neighbor affidavits and voter records.
- RTC and Court of Appeals (CA) Rulings
- The RTC rendered judgment nullifying the MTC decision for lack of jurisdiction and awarded respondent ₱50,000 each for actual damages, moral damages, exemplary damages, attorney’s fees, plus costs.
- On May 6, 2003, the CA affirmed with modifications, holding the forcible entry action as quasi in rem requiring extraterritorial service under Rule 14, §§ 15–16, without which service was invalid.
- Petition for Review to the Supreme Court
- The petitioner filed a Rule 45 petition assailing the CA’s characterization of the action and the finding of invalid service.
- The sole issue before the Supreme Court became: Was service of summons on respondent valid under the Rules of Court?
Issues:
- Whether a forcible entry action is in personam or quasi in rem.
- Whether there was valid service of the summons and complaint on respondent under Rule 14 of the Rules of Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)