G.R. No. 201631, December 7, 2021
ANGELINA DAYRIT, REPRESENTED BY JULIE E. DAYRIT, PETITIONER, VS. JOSE I. NORQUILLAS, ROGELIO I. NORQUILLAS, ROMIE I. NORQUILLAS, HERDANNY I. NORQUILLAS, DANILO M. NORQUILLAS, ANTHONY APUS, TECLO P. MUGOT, ALLAN A. OMPOC, JONI CLARIN, CANDELARIA MEJORADA, LILIA O. TAGANAS, SYLVIA SABAYANON, ARSENIO CATIIL, VERONICO MAESTRE, AND MARIO TAGAYLO, RESPONDENTS.

FACTS

Petitioner Angelina Dayrit was the registered owner of two parcels of agricultural land in Bolisong, El Salvador, Misamis Oriental. In 1993, the lands were placed under the Comprehensive Agrarian Reform Program (CARP) coverage. Consequently, Angelina’s titles were cancelled, and Certificates of Land Ownership Award (CLOAs) were issued in favor of the respondents as agrarian reform beneficiaries. Angelina filed a petition for annulment of the CLOAs before the Department of Agrarian Reform Adjudication Board (DARAB) and also applied for exemption from CARP coverage with the Department of Agrarian Reform (DAR). While the DARAB petition was pending, Angelina alleged that on September 17, 2006, the respondents surreptitiously entered the property and refused to vacate despite demands. This prompted Angelina to file a complaint for forcible entry before the Municipal Circuit Trial Court (MCTC) against the respondents. The respondents, in their answer, acknowledged Angelina’s previous ownership but asserted that they became the owners by virtue of the CLOAs and that Angelina consequently lost her right of possession. The MCTC ruled in favor of Angelina, ordering the respondents to vacate the land. This decision was affirmed by the Regional Trial Court (RTC). The Court of Appeals (CA) reversed the lower courts, dismissing the forcible entry complaint for lack of jurisdiction, ruling that the issue of possession was linked to an agrarian dispute cognizable by the DARAB, and also on the ground of litis pendentia due to the pending DARAB case.

ISSUE

Whether the Court of Appeals erred in dismissing the complaint for forcible entry on the grounds of lack of jurisdiction and litis pendentia.

RULING

The Supreme Court REVERSED the Court of Appeals Decision and REINSTATED the Decisions of the Municipal Circuit Trial Court and the Regional Trial Court. The Court held that the MCTC properly exercised jurisdiction over the forcible entry case. The action was one for ejectment, the sole issue of which was physical or material possession (possession de facto) independent of any claim of ownership. The summary nature of ejectment suits is designed to prevent breaches of peace and criminal disorder and to compel the party out of possession to respect and resort to the law alone to obtain what he claims is his. The Court ruled that the issuance of the CLOAs to the respondents did not automatically entitle them to take possession of the land prior to the final resolution of the landowner’s challenge to the validity of those CLOAs. The pendency of the DARAB case for annulment of the CLOAs did not divest the MCTC of its jurisdiction over the ejectment case, as the issue of physical possession in an ejectment suit is separate from the issue of ownership or the validity of the CLOAs, which is an agrarian dispute. The principle of litis pendentia was also not applicable because there was no identity of causes of action between the forcible entry case (which involved possession de facto) and the DARAB case (which involved the annulment of the CLOAs and the determination of rights as agrarian reform beneficiaries). Therefore, the MCTC had jurisdiction to hear and decide the forcible entry case.