G.R. No. L-73380 March 21, 1988
MARTE SACLOLO, petitioner, vs. HONORABLE INTERMEDIATE APPELLATE COURT and ELEUTERIO PEREA, respondents.

FACTS

Petitioner Marte Saclolo acquired a parcel of land from the Bureau of Lands and obtained a Transfer Certificate of Title in 1979. He then demanded that private respondent Eleuterio Perea vacate the property. Upon Perea’s refusal, Saclolo filed a complaint for forcible entry (later amended to include “or unlawful detainer”) with the Municipal Trial Court (MTC) of Naic, Cavite. Saclolo alleged that Perea, along with others, entered the land through “force, intimidation, threat, strategy or stealth” in August 1979, depriving him of possession. Perea countered that he had been occupying the land since 1958 and that Saclolo’s title was fraudulently obtained.
The MTC ruled in favor of Saclolo, ordering Perea to vacate and pay rentals, characterizing Perea as a “tenant by tolerance.” Perea appealed to the Regional Trial Court (RTC), which set aside the MTC decision, declaring all proceedings null and void for lack of jurisdiction. The RTC found the case was not a proper ejectment suit but an accion publiciana, as the complaint lacked allegations of Saclolo’s prior physical possession or that Perea’s possession began by force or under a contract that was terminated. The Intermediate Appellate Court affirmed the RTC’s ruling.

ISSUE

Whether the Municipal Trial Court had jurisdiction over the complaint filed by petitioner, or whether the case was an accion publiciana beyond its jurisdiction.

RULING

The Supreme Court REVERSED the decisions of the appellate courts and REINSTATED the MTC judgment. The legal logic centers on the nature of unlawful detainer. The Court held that the MTC correctly acquired jurisdiction. While the complaint’s allegations of “force, intimidation, threat, strategy or stealth” were not proven, the amended complaint sufficiently alleged a case for unlawful detainer. The core of unlawful detainer is the withholding of possession after the expiration or termination of the right to hold under contract, express or implied.
The Court found that Perea’s possession, initially as a squatter on public land, became one of mere tolerance when Saclolo acquired title. The government’s prior tolerance was transferred to Saclolo as the new owner. Upon Saclolo’s demand to vacate, Perea’s continued possession became unlawful. The one-year period for filing an unlawful detainer case commenced from the date of the final demand to vacate, which was made in 1979, and the complaint was timely filed. Therefore, the MTC had jurisdiction over the summary action for ejectment. The failure to prove forcible entry did not divest the MTC of jurisdiction, as the allegations in the complaint, construed liberally, established a cause for unlawful detainer based on termination of tolerance.