Case Summary (G.R. No. 205832)
Applicable Law
This case is analyzed under the provisions of the 1987 Philippine Constitution and relevant rules of procedure, specifically Rule 70 of the Rules of Court governing actions for ejectment.
Factual Background and Court Proceedings
The case began on February 25, 2006, when the Abad siblings filed a complaint for forcible entry against Palajos and several others in the Metropolitan Trial Court (MeTC) of Quezon City. They alleged that they were the registered owners of the disputed property, having acquired it from their parents in 1999. They claimed possession initiated in 2001 was forcibly interrupted by Palajos' unlawful act of constructing his residence on the property. Following this, the plaintiffs sought damages for their loss of possession.
In response, Palajos asserted that he had legal possession of Lot No. 5 based on a May 4, 1988 deed of absolute sale. He also presented various pieces of evidence to support his claim to prior possession.
Ruling of the Metropolitan Trial Court
The MeTC ruled in favor of the Abads on September 21, 2007, determining that they had established prior possession through the construction of a perimeter fence and ordered the defendants to vacate the properties and compensate the plaintiffs for damages.
Ruling of the Regional Trial Court
Palajos appealed the MeTC decision. On August 28, 2009, the Regional Trial Court (RTC) reversed the MeTC ruling, concluding that the plaintiffs had not sufficiently proven prior possession, resulting in a dismissal of the forcible entry complaint.
Ruling of the Court of Appeals
The Abads filed a petition for review with the Court of Appeals (CA), which, on September 4, 2012, reinstated the MeTC’s decision, finding that the plaintiffs indeed had prior physical possession of the property. The CA determined that the Abads demonstrated this possession through the construction of a perimeter fence and the legal act of acquiring the title to the property.
Legal Issues Raised
In his petition, Palajos raised two principal issues: the alleged error of the CA in disregarding evidence that he had superior possession of Lot No. 5, and the CA's finding that Palajos' entry onto the property was conducted clandestinely.
Court of Appeals' Justification
The CA reiterated that, in forcible entry cases, the focus is on prior physical possession rather than legal ownership. It found that the question of ownership was subsumed in the issue of possession, allowing for provisional resolution of ownership to establish prior possession. The court also expressed that the Abads had met the requirement of establishing a prima facie case of prior possession.
Determination of Possession and Timing of Action
The Supreme Court upheld the finding
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Case Overview
- The case involves a Petition for Review on Certiorari challenging the September 4, 2012 Decision and the February 7, 2013 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 111323.
- The core issue is the determination of prior possession of a disputed property between Gorgonio P. Palajos (petitioner) and Jose Manolo E. Abad (respondent).
Antecedents
- On February 25, 2006, Jose Manolo E. Abad and his siblings filed a complaint for forcible entry against Palajos and others in the Metropolitan Trial Court (MeTC) of Quezon City, which was docketed as Civil Case No. 06-35654.
- The plaintiffs claimed ownership of three adjacent parcels of land and asserted that they had been in possession since 2001 when they constructed a perimeter fence.
- The plaintiffs alleged that in January 2006, they discovered that the defendants had unlawfully entered the property, damaging their fence and constructing houses.
Claims of the Parties
- The plaintiffs claimed they suffered damages due to the defendants’ unlawful possession, seeking compensatory damages of at least P30,000 monthly.
- Palajos contended he had prior possession of Lot No. 5 based on a May 4, 1988 deed of absolute sale and supported his claim with evidence of tax payments and other documents indicating his residence on the property.
Ruling of the Metropolitan Trial Court (MeTC)
- On September 21, 2007, the MeTC ruled in favor of the plaintiffs, recognizing their prior physical possession due to the constructed perimeter fence.
- The MeTC or