Case Summary (G.R. No. 222523)
Jurisdictional Allegations
In filings, Abad asserted that he and his wife leased the property back to Teresita post-purchase, expecting her to manage the boarding house business. However, after Teresita suddenly abandoned the property, the Abads encountered resistance from Oscar and Daisy, who contended that they were rightful occupants of the property based on inheritance and claimed lifelong possession dating back to 1967.
Court Proceedings and Claims
On March 10, 2003, the Abads filed a complaint for forcible entry before the Metropolitan Trial Court (MeTC) of Quezon City. Oscar and Daisy denied forcibly taking possession and stated that their familial ties to the deceased owner entitled them to the property. The MeTC ruled in favor of the Abads, establishing that they, as registered owners, were entitled to possession of the property.
Regional Trial Court Findings
Oscar and Daisy appealed the MeTC decision to the Regional Trial Court (RTC) of Quezon City, which upheld the MeTC's ruling, asserting that the jurisdictional requirements for forcible entry were met since the Abads were presumed to have prior possession based on their ownership.
Court of Appeals Decision
Subsequent to that, a petition was filed with the Court of Appeals, which found that the MeTC lacked jurisdiction over the case. The Court emphasized that the Abads failed to establish prior physical possession, which is a necessary element in forcible entry actions. The CA asserted that the Abads merely alleged ownership without proving prior possession, leading to the annulment of both the MeTC and RTC decisions.
Legal Standards for Forcible Entry
The Court highlighted that two crucial allegations need to be demonstrated in forcible entry cases: first, the plaintiff's prior physical possession of the property, and second, the defendant's forced removal of that possession. The ruling observed that while Abad claimed a right to possession based on ownership, it did not equate to actual prior physical possession, which is vital to meet jurisdictional requirements.
Rebuttal to Petitioner’s Arguments
Abad attempted to argue that his leasing out of the property after purchase constituted prior possession. However, the evidence from Oscar and Daisy substantiated their claims of prior physical o
...continue readingCase Syllabus (G.R. No. 222523)
Case Overview
- This case revolves around the issues of jurisdiction in forcible entry actions, specifically the necessity for the plaintiff to allege and prove prior physical possession of the property in question.
- The petitioner, Servillano E. Abad, claims that he was forcibly dispossessed of his property by the respondents, Oscar C. Farrales and Daisy C. Farrales-Villamayor.
Facts of the Case
- On August 6, 2002, Servillano Abad and his wife purchased a 428-square meter property located at 7 Administration St., GSIS Village, Project 8, Quezon City, from Teresita, Rommel, and Dennis Farrales, who were related to the respondents.
- The Abads did not plan to operate the boarding house previously run by Teresita and instead leased the property back to her for P30,000.00 per month.
- The boarding house was initially running smoothly until Teresita abandoned it, prompting the Abads to engage Bencio Duran, Teresita's helper, to manage the business.
- On December 8, 2002, Oscar and Daisy, along with two men, forcibly took possession of the property, alarming the house painters working there.
- The Abads sought police assistance but were told that the intruders had left.
- Two days later, on December 10, 2002, Oscar and Daisy forcibly re-entered the property.
- Consequently, on March 10, 2003, Abad filed a complaint for forcible entry against Oscar and Daisy in the Metropolitan Trial Court (MeTC) of Quezon City.
Respondents' Claims
- Oscar and Daisy denied forcibly seizing the property, asserting ownership by inheritance and claiming continuous possession since their birth.
- Oscar claimed residence on the property since 1967, supported by a Barangay certification.
- Daisy admitted to leaving the