Case Summary (G.R. No. 73380)
Background of the Dispute
On September 26, 1979, Saclolo demanded that Perea vacate the lot. When Perea refused, Saclolo initiated an action for forcible entry on October 13, 1979, asserting that Perea and five co-defendants had unlawfully occupied the property. Saclolo alleged they constructed shacks on the land and denied him possession, causing him damages. He sought the defendants' eviction and claimed damages and attorney's fees.
Proceedings in Lower Courts
The case underwent several changes, including amendments to the complaint adding defendants and altering the nature of the claim to include unlawful detainer. Perea contested the complaint and claimed he had occupied the land since 1958, asserting the sale to Saclolo was fraudulent. The Municipal Trial Court ruled in Saclolo's favor, ordering Perea to vacate and awarding damages.
Regional Trial Court Ruling
Perea appealed the decision, leading to a ruling by the Regional Trial Court in June 1984, which declared all proceedings in the Municipal Trial Court null and void due to lack of jurisdiction. It categorized the action as an "accion publiciana," indicating that the Municipal Trial Court did not have the requisite jurisdiction over the case.
Intermediate Appellate Court's Affirmation
The decision of the Regional Trial Court was upheld by the Intermediate Appellate Court, which also found that the Municipal Trial Court lacked jurisdiction. Both courts noted the absence of key allegations in Saclolo's complaint, specifically regarding prior physical possession and the nature of Perea's possession.
Appeal to the Supreme Court
Saclolo escalated the matter to the Supreme Court, alleging several errors by the Intermediate Appellate Court. He contended that the complaint originally filed was sufficient for unlawful detainer and that the courts failed to recognize elements necessary to support his claim.
Jurisdiction Over Forcible Entry vs. Unlawful Detainer
The legal question focused on whether the action constituted forcible entry or unlawful detainer, which are under the jurisdiction of lower courts as per Section 88 of R.A. 296 and Batas Pambansa Bilang 129. The Supreme Court underscored that for a forcible entry claim, the plaintiff must demonstrate prior physical possession and that they were unlawfully
...continue readingCase Syllabus (G.R. No. 73380)
Case Background
- The case arises from an appeal by certiorari from the Intermediate Appellate Court's decision in AC-G.R. SP No. 04070.
- The Intermediate Appellate Court upheld the Regional Trial Court's ruling, which nullified the Municipal Trial Court's proceedings due to lack of jurisdiction.
- The controversy pertains to a portion of Lot No. 6001 SWO-000405 located in Naic, Cavite.
Petitioner’s Claim
- Petitioner Marte Saclolo obtained TCT No. T-114636 through Sales Certificate No. V-345 issued by the Director of Lands on August 22, 1979.
- Petitioner declared the land for taxation, receiving tax declaration No. 8153 in his name.
- On September 26, 1979, petitioner sent a demand letter to private respondent Eleuterio Perea to vacate the property, which Perea refused.
- Consequently, petitioner filed an action for forcible entry on October 13, 1979, alleging that Perea entered the property through "force, intimidation, threat, strategy or stealth."
Complaint and Amendments
- The initial complaint accused Perea and five co-defendants of illegally occupying the property, praying for their eviction and damages.
- On December 24, 1979, the complaint was amended to add two more defendants and to change the title to include "or unlawful detainer."
Private Respondent’s Defense
- Respondent Perea denied the allegations, claiming he had occupied the land since 1958.
- He asserted that petitioner fraudulently obtained the property and demanded damages due to the malicious filing of the complaint.
- The other co-defendants were declared in default after failing to file an answer.
Trial Court Proceedings
- An ex-parte he