G.R. No. 153628 ; July 20, 2006
Anacleto Santiago, petitioner, vs. Pilar Development Corp. and Court of Appeals, respondents.

FACTS

Petitioner Anacleto Santiago filed a complaint for forcible entry against respondent Pilar Development Corp. before the Municipal Trial Court (MTC) of Dasmariñas, Cavite. He alleged prior physical possession of a parcel of land since 1967 and claimed that the respondent unlawfully ejected him by force, intimidation, strategy, and stealth around February 1996. The MTC ruled in favor of Santiago, ordering Pilar Development to vacate the property and pay monthly compensation and attorney’s fees. On appeal, the Regional Trial Court (RTC) initially affirmed the MTC decision but later granted Pilar Development’s motion for reconsideration and dismissed the complaint.
The RTC, upon reconsideration, found Santiago’s claim of prior possession to be based solely on self-serving statements, while Pilar Development’s possession was supported by a Transfer Certificate of Title (TCT) issued to its predecessor-in-interest in 1958. Santiago elevated the case to the Court of Appeals (CA), which affirmed the RTC’s dismissal. The CA noted that Santiago’s own witnesses stated they became his caretakers only in November 1993, after his acquisition of the property, thereby failing to substantiate his claim of possession since 1967.

ISSUE

Whether the Court of Appeals erred in dismissing the forcible entry complaint by relying on evidence of title to resolve the issue of prior physical possession.

RULING

The Supreme Court denied the petition and affirmed the CA decision. The Court reiterated that the sole issue in a forcible entry case is prior physical possession or possession de facto. While the trial court is generally prohibited from delving into ownership, it may provisionally resolve questions of title if such determination is indispensable to deciding the issue of prior possession. Any pronouncement on ownership in such a case remains provisional and does not bar a separate action for title.
In this case, the appellate court’s reference to the TCTs was justified because the evidence on prior possession was directly tied to the question of who had a better right stemming from ownership. The CA found Santiago’s testimonial evidence inconsistent and lacking probative value. In contrast, Pilar Development presented a TCT dating back to 1958, which antedated Santiago’s title from 1993 by nearly two decades. Given the weakness of Santiago’s evidence, the CA correctly used the documentary evidence of title as a basis to conclude that he failed to prove prior physical possession by preponderance of evidence. No reversible error was committed.