G.R. No. 219558. October 19, 2016.
HEIRS OF JOHNNY AOAS, REPRESENTED BY BETTY PUCAY, PETITIONERS, VS. JULIET AS-IL, RESPONDENT.

FACTS

Respondent Juliet As-il filed a complaint for forcible entry against the Heirs of Johnny Aoas before the Municipal Trial Court (MTC). As-il claimed prior physical possession of a 42-square-meter lot covered by her Transfer Certificate of Title (TCT) No. T-57645, alleging that the Heirs of Aoas, by stealth and strategy, initiated construction on the land in January 2005, thereby dispossessing her. The Heirs of Aoas countered that the area was part of their own titled property under TCT No. T-32507, where they had constructed improvements openly. A joint relocation survey confirmed an overlap between the two titled properties, indicating a boundary conflict. The MTC ruled in favor of As-il, prioritizing her prior possession, and ordered the Heirs to vacate. The Regional Trial Court (RTC) initially affirmed this but later reversed itself upon reconsideration, giving weight to a tax declaration of the Heirs that suggested possession prior to 2000. The Court of Appeals reinstated the MTC decision, ruling that the tax declaration was a new issue improperly raised for the first time on appeal before the RTC.

ISSUE

Whether the complaint for forcible entry is the proper remedy to resolve the dispute between the parties.

RULING

No. The Supreme Court granted the petition and dismissed the forcible entry case without prejudice. The Court clarified that the core of the controversy was not a simple question of prior physical possession (de facto possession), which is the sole issue in a forcible entry case. Instead, the joint survey established that both parties held certificates of title over their respective properties, and the dispute arose from an overlapping of boundaries or an encroachment. This transformed the case into a boundary dispute, which inherently involves a determination of ownership or the correct location of property lines based on the titles. Such a complex issue cannot be resolved in the summary proceedings prescribed for ejectment cases under Rule 70 of the Rules of Court. Forcible entry proceedings are limited to determining who had prior physical possession; they are not equipped to adjudicate questions of title or boundary encroachment. Therefore, the MTC acted without jurisdiction over the subject matter. The proper recourse for the parties is to file an appropriate action, such as an accion reivindicatoria (recovery of ownership) or a quieting of title case, in the proper court where issues of ownership and boundary can be fully ventilated.