G.R. No. L-56449 August 31, 1987
JOSE CHING AND CARIDAD CHING, petitioners, vs. Hon. MAXIMIANO C. ASUNCION, as Presiding Judge of the CFI of Laguna Branch II, and Spouses CESAR ALVARADO and ARACELI ALVARADO, respondents.

FACTS

Petitioners Jose and Caridad Ching filed a complaint for forcible entry with the Municipal Court of San Pablo City, alleging that the private respondents, spouses Cesar and Araceli Alvarado, forcibly entered a residential house and lot and refused to vacate despite demands. The petitioners anchored their right to possession on ownership acquired through a valid sale, supported by a Transfer Certificate of Title (TCT) registered in Jose Ching’s name. In their answer, the private respondents claimed ownership by right of inheritance, arguing that the basic issue was one of title, thereby divesting the municipal court of jurisdiction.
The municipal court affirmed its jurisdiction, tried the case, and rendered a decision ordering the respondents to vacate, pay back rentals, and shoulder attorney’s fees. On appeal, the Court of First Instance (CFI) reversed, holding that the municipal court lacked competence as the case involved a question of ownership. The petitioners elevated the matter to the Supreme Court via certiorari.

ISSUE

Whether the municipal court was divested of its jurisdiction over the forcible entry case due to the parties’ assertions of ownership over the disputed property.

RULING

No. The Supreme Court granted the petition, reinstated the municipal court’s decision, and held that the municipal court retained jurisdiction. The Court applied Republic Act No. 296 , as amended, the law in force at the time of filing. Under Section 88, a municipal court has original jurisdiction over forcible entry cases and is expressly permitted to receive evidence on the question of title, but solely for the purpose of determining the character and extent of possession and damages for detention.
The nature of an action, and thus jurisdiction, is determined by the allegations in the complaint. The complaint unequivocally alleged forcible entry, placing it under the municipal court’s summary jurisdiction. The Court reiterated the settled rule that a mere assertion of ownership by the defendant does not oust the municipal court of jurisdiction. Jurisdiction is lost only when, based on the evidence presented, the issue of possession cannot be resolved without first settling the issue of ownership.
Examining the records, the case did not fall under this exception. The petitioners’ title was evidenced by a TCT, presumed valid and unchallenged by any annotated adverse claim. The respondents’ claim, based on an inheritance from a previous owner who had already alienated the property, was deemed untimely and untenable, as no partition of the estate had been effected. Furthermore, the petitioners’ introduction of ownership evidence was permissible under the law to prove the character of their possession and the basis for damages. Therefore, the CFI erred in nullifying the municipal court’s judgment for lack of jurisdiction.