GR 149118; (February, 2006) (Digest)
G.R. No. 149118 February 16, 2006
FLAVIANA LIM CAJAYON and CARMELITA LIM CONSTANTINO, Petitioners, vs. SPOUSES SANTIAGO and FORTUNATA BATUYONG, Respondents.
FACTS
Petitioners and Isagani Candelaria were co-owners of a lot. They partitioned it in 1995, with a portion (Lot 6-A) adjudicated to Candelaria. Candelaria subsequently sold Lot 6-A to respondents. In 1996, petitioners constructed a building. Respondents alleged it encroached on their lot. The parties agreed to a verification survey by a government geodetic engineer, which confirmed that petitioners’ construction occupied 20.61 square meters of respondents’ property, including a portion used as a right of way.
Despite the survey results and subsequent demands to vacate, petitioners refused to leave the encroached area. Respondents then filed an ejectment complaint. The Metropolitan Trial Court (MeTC) ruled in favor of respondents, ordering petitioners to vacate and pay rental compensation. The Regional Trial Court (RTC) affirmed the decision. Petitioners elevated the case to the Court of Appeals, arguing lack of jurisdiction and contesting the survey findings.
ISSUE
Whether the MeTC had jurisdiction over the ejectment case and whether petitioners’ encroachment was sufficiently established.
RULING
The Supreme Court affirmed the Court of Appeals’ decision, upholding the MeTC’s jurisdiction and the finding of encroachment. The complaint sufficiently alleged a cause of action for unlawful detainer. It stated petitioners’ entry by means of construction, respondents’ tolerance of the initial construction pending survey, and the subsequent demand to vacate upon confirmation of encroachment, which petitioners refused. Jurisdiction in ejectment is determined by the allegations in the complaint, and these allegations clearly fell within the MeTC’s exclusive original jurisdiction.
The Court also upheld the factual findings of encroachment based on the verification survey report. The survey was conducted by a government engineer in the presence of the parties. Petitioners’ active participation in the survey process, without timely objection, constituted an implied admission of its validity. Factual findings of the lower courts, especially when affirmed by the Court of Appeals, are generally conclusive and binding. The survey enjoyed the presumption of regularity, and petitioners failed to present strong evidence to rebut this presumption or to disprove the established encroachment.