G.R. No. L-20521 December 28, 1964
ISAIAS ANGCAO, ET AL., plaintiffs-appellants, vs. JOSE PUNZALAN, RICARDO C. REYES, Justice of the Peace of Samal, Bataan, and PEDRO ALDEA, Provincial Sheriff Ex-Officio of Bataan, defendants-appellees.

FACTS

On March 14, 1957, Jose Punzalan filed a complaint for ejectment (Civil Case No. 100) with the Justice of the Peace (JP) Court of Samal, Bataan, against Isaias Angcao and others. Punzalan alleged he had a Homestead Application approved by the Bureau of Lands on November 15, 1933, and was in legal and actual occupancy of the land until March 30, 1956, when Angcao and others forcibly took possession. The defendants contested the JP Court’s jurisdiction, claiming the land was part of a communal forest. The JP Court ruled in favor of Punzalan, finding the land was within an alienable and disposable area, and ordered defendants to vacate. This judgment became final and executory as defendants did not appeal. A writ of execution was issued.
On April 15, 1959, Angcao et al. filed a petition for Certiorari with the Court of First Instance (CFI) of Bataan (Civil Case No. 2587), seeking to declare the JP Court proceedings void for lack of jurisdiction, again asserting the land was part of the public domain. The CFI dismissed the petition on November 5, 1959, for being improper (as no appeal was taken from the JP decision) and for lack of personality of petitioners (as the Government should be the one to seek annulment if the land were public). No appeal was taken from this dismissal.
On February 23, 1960, Punzalan moved for execution of the JP Court decision, which was granted. On April 18, 1960, Angcao et al. filed another action for injunction with the CFI, this time alleging the land was within the Bataan National Park and thus not alienable, rendering the JP judgment null and void. The defendants moved to dismiss, claiming the action was barred by prior judgment and plaintiffs lacked capacity to sue. The CFI dismissed the case, and plaintiffs appealed to the Court of Appeals, which certified the case to the Supreme Court as involving purely legal issues.

ISSUE

1. Whether the Justice of the Peace Court had jurisdiction over the ejectment case (Civil Case No. 100).
2. Whether the present action is barred by prior judgment.

RULING

1. Yes, the JP Court had jurisdiction. The elements for an ejectment action were present: Punzalan had prior possession under an approved Homestead Application since 1933, and was allegedly deprived of it by force. JP Courts have exclusive jurisdiction over ejectment cases where the issue is prior possession. The claim that the land was part of a communal forest or national park does not negate jurisdiction, as the issue in ejectment is possession, not title. An entryman on public land authorized by the Bureau of Lands can seek court protection for his peaceful possession against intruders. The JP Court’s finding that the land was alienable and disposable, and that Punzalan had prior possession, was conclusive as the judgment became final.
2. Yes, the action is barred by prior judgment. The matter of jurisdiction and possession was already passed upon by the JP Court in its final and executory decision in Civil Case No. 100. The subsequent petition for certiorari (Civil Case No. 2587) was also dismissed, and that dismissal became final. The instant case is a second attempt to reopen issues settled by a valid judgment, constituting res judicata or bar by prior judgment. Therefore, no cause of action exists against the respondents.
The Supreme Court dismissed the appeal and affirmed the CFI’s dismissal. Double costs were imposed against petitioners.