Case Digest (G.R. No. L-22984)
Facts:
- Margarito Sarona and others (plaintiffs-appellants) filed a complaint against Felipe Villegas and Ramona Carillo (defendants-appellees) on January 28, 1963, in the Municipal Court of Padada, Davao.
- Plaintiffs claimed to be the absolute owners and possessors of a parcel of land in Paligue, Padada.
- They alleged that on April 1, 1958, the defendants unlawfully entered the land, constructed a residential house, and remained in possession, thereby unlawfully withholding possession from the plaintiffs.
- On December 28, 1962, the plaintiffs demanded that the defendants vacate the premises and pay rentals in arrears, but the defendants refused.
- Plaintiffs sought to be restored to possession and demanded payment of rents, attorney's fees, and litigation expenses.
- Defendants moved to dismiss the complaint for lack of jurisdiction, arguing that the case was one of forcible entry, which should have been filed within one year of the entry.
- The Municipal Court denied the motion and ruled in favor of the plaintiffs, ordering the defendants to vacate and pay rentals.
- On appeal, the Court of First Instance of Davao dismissed the case, ruling it was one of forcible entry filed beyond the one-year period.
- Plaintiffs then appealed to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the case was one of forcible entry.
- The Supreme Court affirmed the dismissal of the case by the Court of First Instance of Dava...(Unlock)
Ratio:
- Section 1, Rule 70 of the Revised Rules of Court defines two distinct causes of action: forcible entry and unlawful detainer.
- The nature of the defendant's entry determines the cause of action.
- Forcible entry involves illegal occupation from the beginning and must be filed within one year from such entry.
- Unlawful detainer involves initially lawful possession that becomes illegal, requiring filing within one year from the last demand to vacate.
- The complaint lacked specific allegations about the nature of the defendants' entry, whether legal or illegal.
- Evidence revealed that the defendants entered the land without consent on April 1, 1958, making it a case of forcible entry.
- Since the complaint was fil...continue reading
Case Digest (G.R. No. L-22984)
Facts:
The case involves plaintiffs-appellants Margarito Sarona and others against defendants-appellees Felipe Villegas and Ramona Carillo. The dispute centers around a parcel of land located in Paligue, Padada, Davao. On January 28, 1963, the plaintiffs filed a complaint for "Unlawful Detainer" in the Municipal Court of Padada, asserting that they were the absolute owners and in possession of the land. They claimed that the defendants entered the property on April 1, 1958, constructed a residential house, and unlawfully withheld possession from the plaintiffs. The plaintiffs demanded that the defendants vacate the premises and pay back rent of P20.00 per month, which the defendants failed to do.
In response, the defendants filed a motion to dismiss, arguing that the municipal court lacked jurisdiction because the case was one of forcible entry, and the one-year period for filing such a case had elapsed. The municipal court denied the motion to dismiss and later ruled in favor of the plaintiffs, ordering the defendants to vacate the property and pay monthly rent and attorney's fees. The defendants appealed to the Court of First Instance of Davao, which dismissed the case, stating that it was indeed a case of forcible entry initiated beyond the one-year period. The plaintiffs then appealed to the Supreme Court, contending that the municipal court had original jurisdict...