G.R. No. L-33213. June 29, 1979.
ARTEMIO C. REYES and HILARION C. REYES, petitioners, vs. HON. ANDRES STA. MARIA, Presiding Judge, Court of First Instance of Bulacan, Branch II, HILARIA SANTOS VDA. DE LOPEZ and PILAR SANTOS, respondents.

FACTS

Petitioners Artemio and Hilarion Reyes filed a complaint in the Court of First Instance of Bulacan to quiet title and recover possession of a residential lot in Hagonoy, Bulacan. They alleged they are the pro-indiviso owners of the property, which respondents Hilaria Santos Vda. de Lopez and Pilar Santos occupied through tolerance under an agreement to pay real estate taxes and to vacate upon demand. In February 1968, petitioners demanded that respondents vacate as they needed the land, but respondents refused, claiming they had bought the property from a certain Pablo Aguinaldo. The complaint prayed for a declaration of petitioners’ ownership, an order for respondents to vacate, and an award of monthly rental damages and attorney’s fees.
Respondents moved to dismiss the complaint on the ground of lack of jurisdiction, contending the action was essentially for unlawful detainer falling within the exclusive original jurisdiction of the municipal court. The lower court agreed, finding the factual averments constitutive only of an unlawful detainer case and insufficient to support an action to quiet title. It dismissed the case, prompting petitioners to seek review directly with the Supreme Court.

ISSUE

Whether the lower court correctly dismissed the complaint for lack of jurisdiction on the ground that it alleged only a cause of action for unlawful detainer.

RULING

No. The Supreme Court set aside the dismissal order, holding that the lower court committed a reversible error. The complaint, on its face, revealed a dispute that transcended mere physical possession. Respondents’ refusal to vacate was predicated on an adverse claim of ownership, alleging purchase from a third party. This transformed the nature of the suit from a simple action for detainer (which recovers only physical possession or possession de facto and must be filed within one year in the municipal court) into either an accion publiciana or an accion reivindicatoria.
An accion publiciana is a plenary action for the recovery of the right to possess (possession de jure), while an accion reivindicatoria seeks recovery of ownership. Both actions fall within the original jurisdiction of the Court of First Instance. The Court, citing Moran, clarified the distinctions among possessory actions. Since the core issue involved a conflict over the better right of possession, if not ownership itself, arising from respondents’ assertion of a rival title, the case was at the very least an accion publiciana. The lower court therefore had jurisdiction. The case was remanded for expedited proceedings on the merits.