G.R. No. 232849 , June 14, 2021
Lourdes E. Ruiz, Petitioner, vs. Reynaldo Armada and Delfin Paytone, Respondents.

FACTS

Petitioner Lourdes E. Ruiz filed a Complaint for forcible entry with injunction with the Municipal Circuit Trial Court (MCTC) against respondents Reynaldo Armada and Delfin Paytone. She alleged she is the owner of Magalawa Island, covered by Transfer Certificate of Title (TCT) No. T-54730, and had been in peaceful occupation until December 12, 2008, when respondents, through force, intimidation, stealth, threats, and strategy, entered the property, cut fruit-bearing trees, and constructed houses. Despite demands to vacate, respondents refused. Respondents denied the allegations, claiming respondent Reynaldo Armada is the son of Lucio Armada, the rightful owner of a portion of the land, evidenced by a tax declaration, and denied occupying petitioner’s property. A relocation survey commissioned by the MCTC identified several lots occupied by respondents: Lot 1 (26,131 sq. m. inside TCT No. T-54730), Lot 2 (687 sq. m., portion of Lot 2814, Palauig Cadastre), Lot 3 (1,976 sq. m., accretion), and Lot 2813 (1,208 sq. m., Palauig Cadastre). The MCTC ruled in favor of petitioner, ordering respondents to vacate the specified lots and remove structures. The Regional Trial Court (RTC) reversed the MCTC, holding petitioner failed to prove prior physical possession of Lot 1 and that Lots 2, 3, and 2813 were not included in her complaint. The Court of Appeals (CA) affirmed the RTC, finding no evidence of petitioner’s prior physical possession or control over the property.

ISSUE

Whether petitioner was able to prove her prior physical possession of the subject property, an essential element in a forcible entry case.

RULING

The Supreme Court partially granted the petition. It held that petitioner proved prior physical possession of Lot 1 covered by TCT No. T-54730 but not of Lots 2, 3, and 2813. The Court found that the conclusions of fact by the CA and RTC conflicted with those of the MCTC, justifying a review of factual issues. For Lot 1, the Court considered petitioner’s tax declaration (dating from 1987) in the name of her deceased husband as an earlier and superior indicator of possession compared to respondents’ tax documents. The Court also noted the presence of an old, dilapidated building on the property as evidence of prior possession by petitioner’s predecessors-in-interest, and credited the MCTC’s ocular inspection report which found respondents’ structures were new. The Court emphasized that ownership or titling is not the issue in forcible entry, but prior physical possession, which petitioner established for Lot 1 through juridical acts (tax declaration, title) and the fact of deprivation by respondents on December 12, 2008. However, for Lots 2, 3, and 2813, the complaint pertained only to the property covered by TCT No. T-54730, and petitioner did not show authorization to represent the other lot owners. Thus, the CA decision was affirmed regarding Lots 2, 3, and 2813 but reversed regarding Lot 1. Respondents were ordered to vacate Lot 1, remove structures, and restore possession to petitioner.