Title
Saclolo vs. Intermediate Appellate Court
Case
G.R. No. 73380
Decision Date
Mar 21, 1988
Dispute over Lot No. 6001 in Naic, Cavite; petitioner Saclolo, with valid title, sued Perea for unlawful detainer after Perea refused to vacate. Courts initially dismissed for jurisdiction issues, but SC ruled it was unlawful detainer, ordering Perea to vacate.

Case Digest (G.R. No. 73380)
Expanded Legal Reasoning Model

Facts:

  • Parties and Title to the Property
    • Petitioner: Marte Saclolo, the registered and absolute owner of a portion of Lot No. 6001 SWO-000405 of the Naic Friar Lands Estate, Naic, Cavite, as evidenced by Sales Certificate No. V-345 and Transfer Certificate of Title (TCT No. T-114636).
    • Respondents:
      • The Honorable Intermediate Appellate Court (and its predecessors in the case).
      • Private respondent Eleuterio Perea, among others, who occupied the disputed land.
  • Transactional Background and Pre-Litigation Developments
    • Following the formal acquisition and declaration for taxation (Tax Declaration No. 8153), petitioner sent a registered demand letter dated September 26, 1979 to respondent Perea, asking him to vacate the disputed lot.
    • Private respondent Perea, who had been in possession of a portion of the land since 1958 and had built improvements thereon, refused to vacate despite the notice.
    • On October 13, 1979, petitioner filed an action for forcible entry alleging that in August 1979, respondent Perea and five other co-defendants unlawfully occupied the property by employing “force, intimidation, threat, strategy or stealth.”
  • Allegations and Pleadings
    • Initial Complaint
      • Alleged forcible entry of Lot No. 1023, part of the Naic Friar Lands Estate, which deprived petitioner of possession.
      • Sought relief in the form of ejectment of the defendants, monthly rental damages of P20.00 from October 23, 1979 until vacation, attorney’s fees, and costs.
    • Amendments to the Complaint
      • On December 24, 1979, petitioner amended the complaint to include additional defendants and to append “or unlawful detainer” to the pleading, while incorporating a detailed description of the disputed land.
    • Defendant’s Answer
      • Private respondent Perea entered his Answer on January 14, 1979, denying the allegations.
      • Claimed possession dating back to 1958 and alleged that petitioner defrauded the Bureau of Lands to secure the title.
      • Asserted that the filing of the complaint had resulted in unnecessary attorney’s fees and appearance charges for his legal defense.
  • Proceedings in the Lower Courts
    • Municipal Trial Court
      • An ex-parte presentation was conducted against the defaulting defendants, culminating in a judgment on September 14, 1983.
      • Judgment ordered respondent to vacate the land and ordered payment of monthly rental, attorney’s fees, and costs.
      • The trial court found petitioner’s title sufficient to establish ownership, while categorizing respondent Perea as a “tenant by tolerance” even though the allegations lacked evidence of prior possession and forcible entry by the means mandated by law.
    • Regional Trial Court
      • On appeal by respondent Perea, the Regional Trial Court nullified the ruling of the Municipal Trial Court on the ground of lack of jurisdiction.
      • Determined that the case did not satisfactorily allege either forcible entry or unlawful detainer as required by law, particularly noting the absence of allegations concerning petitioner’s prior physical possession or any express or implied tenancy agreement.
    • Intermediate Appellate Court
      • The then Intermediate Appellate Court, reaffirming the Regional Trial Court’s jurisdictional determination, dismissed petitioner’s petition on its merits.
      • Petitioner’s motion for reconsideration was denied, further escalating the matter to the Supreme Court via a petition for certiorari.
  • Supreme Court Involvement
    • The petition for certiorari questioned whether the case should be classified as one for forcible entry or for unlawful detainer, which would determine the appropriate jurisdiction of the Municipal Trial Court.
    • Issues raised by petitioner included alleged errors in:
      • The Intermediate Appellate Court’s characterization of the action as solely one for forcible entry.
      • The failure to recognize that the amended complaint adequately supported a claim for unlawful detainer.
      • The jurisdictional ruling that the proper remedy should be recovery of possession rather than forcible entry/ejectment.
      • The lack of reversal of the Regional Trial Court’s decision in light of the facts and applicable law.

Issues:

  • Jurisdictional Characterization
    • Whether the case should be classified as an action for forcible entry or unlawful detainer, which would determine whether it falls within the exclusive original jurisdiction of the Municipal Trial Court.
  • Essential Elements Requirement
    • Whether the amended complaint sufficiently alleged the essential elements required for the proper filing of an unlawful detainer action, particularly in the absence of evidence of petitioner’s prior physical possession of the property.
  • Evidentiary Support for Possession Claims
    • Whether petitioner adequately demonstrated that respondent Perea’s occupation was by “force, intimidation, threat, strategy or stealth” or that the possession was originally held by petitioner before being usurped.
  • Proper Relief and Legal Theories
    • Whether the relief sought by petitioner (i.e., ejectment, damages, attorney’s fees) corresponded with the legal requirements for filing an action for forcible entry or unlawful detainer under the Rules of Court, Section 88 of R.A. 296, and B.P. 129.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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