GR 142843; (August, 2003) (Digest)
G.R. No. 142843 ; August 6, 2003
OCTAVIO ALVAREZ, MARILYN CORTEZ, and CHARLIE ROBLES, Petitioners, vs. HON. COURT OF APPEALS and SPOUSES DOMINGO and CELIA GARCIA, Respondents.
FACTS
Spouses Domingo and Celia Garcia purchased a parcel of land in Quezon City in 1978, had it registered and fenced, and then left for the United States. Upon their return in 1995, they discovered their fence removed and portions of their property occupied by persons who had constructed houses. These occupants, identified as Marilyn Cortez and Charlie Robles, claimed they were leasing the property from Octavio Alvarez, who allegedly bought it from one Amparo Lasam. After a failed barangay settlement, the Garcias filed a complaint for forcible entry against Alvarez, Robles, and Cortez with the Metropolitan Trial Court (MeTC).
The MeTC ruled in favor of the Garcias, ordering the petitioners to vacate the property, remove improvements, and pay compensation and attorney’s fees. Petitioners appealed to the Regional Trial Court (RTC) but failed to file a supersedeas bond to stay execution. The RTC affirmed the MeTC decision. The Court of Appeals subsequently denied petitioners’ petition for review, prompting this appeal to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in affirming the lower courts’ decisions which allegedly: (1) improperly ruled on the issue of ownership in a forcible entry case; (2) disregarded petitioners’ claim of prior physical possession; and (3) failed to accord probative value to petitioners’ documentary evidence.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic is anchored on the nature of ejectment cases and the binding effect of factual findings. In forcible entry, the sole issue is physical possession (possession de facto), independent of claims of ownership. The lower courts correctly resolved this issue by determining who had prior physical possession, which was conclusively established to be the respondent spouses. Their prior possession was evidenced by their purchase, registration, and act of fencing the property before departing abroad. The subsequent occupation by petitioners, without the Garcias’ consent, constituted forcible entry.
The Court held that the lower courts did not rule on ownership but merely addressed it preliminarily to resolve the issue of prior possession, which is permissible. Petitioners’ arguments regarding their documents of sale and special power of attorney involve factual assessments, which are beyond the scope of a petition for review under Rule 45. The Supreme Court is not a trier of facts; factual findings of the trial courts, especially when affirmed by the Court of Appeals, are binding and conclusive. No reversible error of law was committed by the appellate court.