GR L 12838; (March, 1918) (Digest)
G.R. No. and Date: G.R. No. L-12838; March 9, 1918
Case Title: FELIX MEDIRAN, plaintiff-appellant, vs. MAXIMIANO VILLANUEVA, ET AL., defendants-appellees.
FACTS:
Plaintiff Felix Mediran filed an action for forcible entry and unlawful detainer in the justice of the peace court of Amadeo, Cavite, against defendants Maximiano, Jacinto, and Pedro Villanueva. Mediran alleged he was in prior possession of a parcel of land until the defendants unlawfully entered and deprived him of possession on or about December 15, 1915. The justice of the peace court ruled in favor of Mediran against Jacinto and Pedro Villanueva (Maximiano was excluded as he had no part in the act). The defendants appealed to the Court of First Instance (CFI) of Cavite. In the CFI, the defendants claimed ownership of the land by inheritance. The CFI ruled in favor of the defendants, prompting Mediran’s appeal to the Supreme Court. The evidence established that Mediran had prior lawful and undisturbed possession of the land for many years, which was interrupted when the defendants entered the land in December 1915, ordered Mediran’s laborers to leave, and threatened Mediran when he confronted them.
ISSUE:
1. Whether the defendants’ acts constituted “force” as required to maintain an action for forcible entry under Section 80 of the Code of Civil Procedure.
2. Whether the assertion of ownership by the defendants divests the inferior court of jurisdiction over the forcible entry case.
RULING:
The Supreme Court reversed the CFI decision and ruled in favor of plaintiff Mediran.
1. On the element of “force”: The Court held that “force” in an action for forcible entry is not limited to violence against a person. The act of entering the property and excluding the lawful possessor necessarily implies the exertion of force over the property. The statute covers entry by “force, intimidation, threat, strategy, or stealth,” encompassing any wrongful entry that excludes a prior possessor. The defendants’ acts of entering the land, ousting Mediran’s laborers, and refusing to leave upon confrontation constituted sufficient force under the law.
The Court ordered defendants Jacinto and Pedro Villanueva to restore possession of the land to Mediran and to pay damages and costs.
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