GR 129247; (March, 2006) (Digest)
G.R. No. 129247 & 136270; March 3, 2006
SPOUSES ARSENIO and NIEVES S. REYES, Petitioners, vs. SOLEMAR DEVELOPMENT CORPORATION and RENATO M. TANSECO, Respondents. x————————x SPOUSES ARSENIO and NIEVES S. REYES, Petitioners, vs. REPUBLIC OF THE PHILIPPINES, Respondent.
FACTS
Petitioners, the Spouses Reyes, filed a Complaint for Damages and Preliminary Injunction with a Prayer for a TRO before the RTC of Makati against Solemar Development Corporation and Renato Tanseco. They alleged they are the registered owners of a parcel of land in Parañaque and that in January 1992, respondent Tanseco, with police assistance, employed force and intimidation to enter the premises, demolish their perimeter fence, and eject them. They sought to enjoin respondents from ousting them without a court order. Respondents countered that they own the property and questioned the authenticity of petitioners’ title.
After procedural skirmishes, including an unsuccessful attempt by petitioners to amend their complaint to include a cause for nullity of title, respondents moved to dismiss the original complaint for lack of jurisdiction. They argued the allegations constituted an action for forcible entry, falling within the exclusive original jurisdiction of the Municipal Trial Court (MTC). The RTC denied the motion, holding that the case involved recovery of possession and damages where ownership was necessarily in issue, thus vesting it with jurisdiction.
ISSUE
Whether the complaint filed by petitioners is an action for forcible entry within the jurisdiction of the MTC or an action for recovery of ownership cognizable by the RTC.
RULING
The Supreme Court affirmed the Court of Appeals’ decision ordering the RTC to dismiss the case for lack of jurisdiction. The Court held that jurisdiction is determined by the allegations in the complaint. A meticulous review of the allegations revealed that the core relief sought by petitioners was the restoration of their peaceful possession of the land, which they claimed was deprived through force, intimidation, and the demolition of their fence by respondents with police aid. The specific averments clearly depicted a recent, unlawful deprivation of possession by means of force and strategy.
The Court ruled that the action was essentially one for forcible entry under Rule 70 of the Rules of Court. The primary objective was to recover physical possession (restitutio in integrum), and the claim for damages was merely incidental to this main relief. The fact that petitioners asserted ownership and that the case could potentially involve an inquiry into title did not alter its fundamental character as a possessory action. Forcible entry cases are designed to provide a speedy remedy for the restoration of physical possession, and jurisdiction is vested in the MTC regardless of any claims of ownership by either party. Since the allegations unequivocally pointed to a forcible entry scenario, the RTC had no jurisdiction over the case.