Case Summary (G.R. No. L-16704)
Due Process and Pleading Requirements
The Supreme Court held that due process did not require the Court of Appeals to demand a formal answer from petitioner because petitioner’s comment filed on February 26, 1986 adequately addressed all issues raised in the petition for review. Both parties were heard, and petitioner further argued its case in its motion for reconsideration. There was thus no deprivation of the right to be heard under the due process clause of the 1987 Constitution.
Right to Forcible Entry by Actual Possessors
The Court reaffirmed that forcible entry is a summary remedy to recover actual, peaceable, and continuous possession unlawfully disturbed; it does not adjudicate ownership. Private respondents were undisputedly in actual possession when petitioner bulldozed their fences and crops. No evidence showed that the Jose spouses ever occupied the land. As long as a party proves prior possession, he may recover it even against the owner, holding title issues for separate accion publiciana or accion reivindicatoria.
Limitation on Self-Help Doctrine
Lower courts justified petitioner’s actions under Article 429 of the Civil Code, which permits self-help at the time of threatened or actual dispossession. The Supreme Court clarified that once possession has been lost, self-help is no longer available; the party must resort to judicial remedies per Article 536. Petitioner’s forcible rem
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Facts
- Spouses Cynthia Cuyegkeng Jose and Manuel Rene Jose, U.S. residents, own a 232,942-sqm parcel in Sitio Inarawan, San Isidro, Antipolo, Rizal, covered by TCT No. 50023 (issued September 11, 1980), which canceled TCT No. 56762/T-560.
- The land was originally registered as OCT No. 19 on August 5, 1948, under a Homestead Patent granted July 27, 1948 pursuant to Act No. 141.
- On February 26, 1982, the spouses Jose executed a Special Power of Attorney authorizing German Management & Services, Inc. (petitioner) to develop the property into a residential subdivision.
- Petitioner secured Development Permit No. 00424 from the Human Settlements Regulatory Commission on February 9, 1983.
- Portions of the property were occupied and cultivated by private respondents (Orlando Gernale, Ernesto Villeza, and twenty others) for 12–15 years prior to PD No. 27.
- Petitioner advised these occupants to vacate; they refused. Petitioner proceeded with development, including bulldozing fenced areas and destroying crops.
Procedural History
- Private respondents filed a forcible entry action against petitioner in the Municipal Trial Court (MTC) of Antipolo, which dismissed their complaint on January 7, 1985.
- On appeal, the Regional Trial Court (RTC), Branch LXXI, Antipolo, Rizal, sustained th