GR 152992; (July, 2005) (Digest)
G.R. No. 152992. July 28, 2005.
LEONARDO DAVID, Petitioner, vs. NELSON and DANNY CORDOVA, Respondents.
FACTS
Petitioner Leonardo David filed a complaint for forcible entry with the Municipal Circuit Trial Court (MCTC) against respondents Nelson and Danny Cordova. David alleged he was a co-owner of Lot 774 and that the Cordovas, through force and intimidation, destroyed its fence and erected a structure on the land in April 1997 without his consent. The MCTC ruled in David’s favor, ordering the Cordovas to vacate and pay compensation. The Cordovas challenged this, filing petitions for certiorari with the Regional Trial Court (RTC), arguing the MCTC lacked jurisdiction. They contended the land was part of a government-owned landed estate under the administration of the Department of Agrarian Reform (DAR), making the case an agrarian dispute beyond the MCTC’s authority. The RTC initially dismissed their petitions. The Cordovas then elevated the matter to the Court of Appeals.
ISSUE
Whether the MCTC had jurisdiction over the forcible entry case, or if jurisdiction properly belonged to the Department of Agrarian Reform because the subject property is allegedly government-owned agricultural land.
RULING
The Supreme Court ruled that the MCTC validly exercised jurisdiction. The Court explained that jurisdiction in forcible entry cases is determined by the allegations in the complaint. David’s complaint sufficiently alleged prior physical possession, deprivation thereof by force, and action filed within one year—the core elements for an accion interdictal under Rule 70. The nature of the action is unaffected by the defendant’s claim of ownership or any tenurial arrangement. The Court emphasized that the MCTC’s jurisdiction is limited to the issue of prior physical possession de facto; it does not adjudicate ownership. Any claim by the Cordovas that the land is government property subject to agrarian reform involves a question of title, which is beyond the summary scope of a forcible entry case. Such a claim does not divest the MCTC of its jurisdiction to resolve the preliminary issue of possession. The proper recourse for the Cordovas was to raise the issue of ownership in an appropriate proceeding before a different court or agency, after the possession issue is settled. The Court of Appeals’ decision was reversed, and the MCTC’s judgment was reinstated.