G.R. No. L-22984 - Sarona vs. Villegas

The Revised Rules of Court delineate two distinct causes of action: forcible entry and unlawful detainer.
Forcible entry pertains to illegal occupation from the outset, while unlawful detainer involves a legal entry that later becomes illegal.
The nature of the defendant's entry determines the appropriate cause of action and the corresponding time frame for filing.
Forcible entry actions must be initiated within one year of the illegal entry, whereas unlawful detainer actions must be filed within one year from the last demand for possession.

Jurisdictional facts must be explicitly stated in the complaint.
In this case, the complaint lacked clarity regarding the nature of the defendants' entry, leading to ambiguity about whether it was a case of forcible entry or unlawful detainer.
The municipal court lacked jurisdiction due to the failure to specify the nature of the entry, which was revealed during the trial to be illegal from the beginning.

Tolerance must be present from the start of possession to categorize an action as unlawful detainer.
The absence of any indication of tolerance in the complaint or during the trial suggests that the defendants' possession was illegal from the outset.
The court emphasized that mere knowledge of the defendants' presence does not equate to tolerance.

If a plaintiff fails to initiate an action within one year, the remedy shifts to a Court of First Instance in an accion publiciana.
The plaintiffs' failure to file within the one-year period for forcible entry necessitated dismissal of the case for lack of jurisdiction.

The plaintiffs' complaint was filed as "Unlawful Detainer," but the facts indicated it was a case of forcible entry.
The defendants' entry was characterized as illegal, and the plaintiffs' demand for vacating the premises was made well beyond the one-year limit for forcible entry actions.
The municipal court's judgment was based on the understanding that the case was one of forcible entry, which was affirmed by the Court of First Instance.

The concept of tolerance, as defined by legal scholars, indicates that mere neighborly acts do not confer legal rights to the possessor.
Tolerance must be established from the beginning of possession to support a claim of unlawful detainer.
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