G.R. No. L-30336 June 30, 1976
FORTUNATO BANAYOS, CONSTANTE BANAYOS and FEDERICO BRINGAS, petitioners, vs. SUSANA REALTY, INC., HONORABLE AMADOR GOMEZ, in his capacity as Judge, Court of First Instance of Rizal, and NICANOR SALAYSAY, in his capacity as Provincial Sheriff of Rizal, respondents.

FACTS

Susana Realty, Inc., as registered owner, filed a complaint for recovery of possession against petitioners, alleging that the latter, by means of strategy and stealth, entered the subject parcels of land in Mandaluyong, Rizal, built houses, and occupied the lots for at least three years prior to the filing of the complaint. The plaintiff corporation demanded that defendants vacate, but they refused. The complaint sought ejectment, removal of structures, and payment of damages for lost rental income. Petitioners were declared in default for filing their answer out of time. The Court of First Instance of Rizal rendered a judgment ordering petitioners to vacate and pay back rentals. Petitioners subsequently filed motions, including a motion to set aside the judgment, arguing that the case was actually one for ejectment (forcible entry or unlawful detainer) over which the municipal court had exclusive original jurisdiction, and thus the CFI lacked jurisdiction.

ISSUE

Whether the Court of First Instance had jurisdiction over the complaint filed by Susana Realty, Inc., or whether it was an ejectment case falling under the exclusive original jurisdiction of the municipal court.

RULING

The Supreme Court ruled that the Court of First Instance correctly exercised jurisdiction. The legal logic hinges on the nature of the action as determined by the allegations of the complaint and the timing of its filing. For an action to be considered forcible entry or unlawful detainer under the exclusive original jurisdiction of the inferior courts, it must be filed within one year from the date of the alleged illegal entry or withholding of possession. The complaint explicitly alleged that petitioners had been in occupation for “at least three (3) years prior” to its filing. This period, being beyond one year, removed the case from the ambit of summary ejectment proceedings. Consequently, the action was properly characterized as an accion publiciana—a plenary action for the recovery of the right to possess, cognizable by the Court of First Instance. The allegation of entry by “strategy and stealth” did not convert it into a forcible entry case given the lapse of the one-year period. The Court emphasized that jurisdiction is determined by the allegations in the complaint and the relief sought. Since the complaint sought recovery of possession after the lapse of more than one year from deprivation, it was an ordinary civil action within the CFI’s jurisdiction. The petition for certiorari was dismissed.