G.R. No. 141962 ; January 25, 2006
DANILO DUMO and SUPREMA DUMO, Petitioners, vs. ERLINDA ESPINAS, JHEAN PACIO, PHOL PACIO, MANNY JUBINAL, CARLITO CAMPOS, and SEVERA ESPINAS, Respondents.

FACTS

Petitioners Danilo and Suprema Dumo filed a complaint for forcible entry with the Municipal Trial Court (MTC) of Bauang, La Union. They alleged they were the owners and prior possessors of a parcel of land. On October 30, 1996, respondents, acting for Severa Espinas, forcibly entered the property, drove out the petitioners, and demolished the structures thereon. Petitioners asserted that a prior case (Civil Case No. 857) involving the same property, wherein respondents were declared owners against other parties, did not bind them as they were not parties thereto. Respondents, in their answer, claimed ownership by virtue of a purchase in 1943 and a favorable decision in Civil Case No. 857, justifying their entry and demolition as an exercise of ownership rights.
The MTC ruled in favor of the petitioners, ordering respondents to vacate and awarding damages. On appeal, the Regional Trial Court (RTC) reversed the MTC, dismissing the complaint. The RTC held that the MTC lacked jurisdiction because the issue of ownership was intertwined with possession, and the property was not capable of pecuniary estimation. The Court of Appeals (CA) then set aside the RTC decision, reinstating the MTC judgment but deleting the awards for lost earnings and moral and exemplary damages for lack of evidentiary basis.

ISSUE

Whether the MTC had jurisdiction over the forcible entry case despite the respondents’ claim of ownership.

RULING

Yes, the MTC retained jurisdiction. The Supreme Court affirmed the CA’s reinstatement of the MTC decision, emphasizing the nature of ejectment suits. In forcible entry cases, the sole issue is physical or material possession (possession de facto), independent of any claim of ownership. Jurisdiction is conferred upon the proper court at the time of the filing of the complaint based on the allegations therein. The petitioners’ complaint sufficiently alleged prior physical possession that was unlawfully deprived by the respondents’ force and intimidation. The respondents’ assertion of ownership, anchored on a prior judgment to which petitioners were not parties, is a matter of defense that does not divest the MTC of its jurisdiction over the possessory action. The Court clarified that the alleged complexity arising from an ownership claim does not oust the inferior court’s jurisdiction, as it is empowered to resolve such claims provisionally for the sole purpose of determining the issue of possession. The awards for lost earnings were correctly deleted for lack of evidentiary support, as damages in ejectment are limited to the fair rental value or compensation for loss of use.