Title
Rosario vs. Carandang
Case
G.R. No. L-7076
Decision Date
Apr 28, 1955
The Supreme Court ruled that forcible entry and detainer cases fall exclusively under the jurisdiction of justice of the peace courts, not the Court of First Instance.
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Case Digest (G.R. No. L-7076)

Facts:

  • The case involves Eriberto P. Rosario and Paz Untalan de Rosario against Filomeno Carandang and others (G.R. No. L-7076).
  • A complaint was filed on October 16, 1952, in the Court of First Instance of Pangasinan.
  • The plaintiffs claimed ownership and possession of a parcel of land (lot No. 2, plan Psu-123111) in Labrador, Pangasinan.
  • They applied for land registration in Registration Case No. 658, G.L.R.O. No. 2610, which the defendants opposed.
  • The plaintiffs alleged that on October 3, 1952, the defendants unlawfully entered the property, destroyed nipa plants, and constructed dikes for a fishpond.
  • The plaintiffs warned the defendants, but they continued to occupy the land, causing damages of P2,000.
  • On November 3, 1952, the defendants filed a motion to dismiss, claiming the case was one of forcible entry and detainer, under the jurisdiction of the Justice of the Peace Court, and that there was another pending action.
  • The plaintiffs opposed the motion, arguing that the Court of First Instance could not award damages in a registration case.
  • The lower court granted the motion to dismiss on November 7, 1952.
  • The plaintiffs filed a motion for reconsideration and sought to admit an amended complaint, which included claims of ownership by the defendants.
  • The lower court denied the motion for reconsideration and the amended complaint, leading to an appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the lower court's dismissal of the plaintiffs' original complaint, confirming it was a case of forcible entry and detainer, under the exclusive jurisdiction of the Justice of the Peace Court.
  • The Supreme Court upheld the lower court's denial of the plaintiffs' motion f...(Unlock)

Ratio:

  • The Supreme Court determined that the original complaint was a clear action for forcible entry and detainer, as the plaintiffs claimed prior possession and deprivation within one year by the defendants.
  • Such cases fall exclusively under the jurisdiction of the Justice of the Peace Courts, irrespective of the claimed damages.
  • The Court clarified that filing an opposition in a registration case does not imply a claim of ownership, and the plaintiffs' assertion of seeking a de...continue reading

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