G.R. No. L-32192 July 30, 1976
ESPERANZA BAPTISTA, assisted by her husband, ARTURO VILLANUEVA, petitioners, vs. URBANO CARILLO, and THE HON. COURT OF APPEALS, respondents.

FACTS

Respondent Urbano Carillo purchased a residential lot in Quezon City from the People’s Homesite and Housing Corporation (PHHC) under a conditional contract of sale dated December 23, 1958. He immediately took possession by fencing the property. In April 1963, Carillo discovered individuals, later identified as petitioners Esperanza Baptista and others, constructing foundations on the lot without a building permit. After reporting the intrusion to city authorities, which yielded no action, Carillo filed a forcible entry complaint in the Municipal Court of Quezon City on June 14, 1963.
The Municipal Court ruled in favor of Carillo, ordering the defendants to vacate and pay rentals. On appeal, the Court of First Instance affirmed the ejectment order but deleted the rental award. The Court of Appeals subsequently affirmed this decision in toto. Petitioners then elevated the case to the Supreme Court via a Petition for Review on certiorari, arguing that the appellate court erred in its factual finding regarding their date of possession and in not recognizing their alleged preferential right to acquire the lot from the PHHC.

ISSUE

The primary issue is whether the Supreme Court can review the factual findings of the Court of Appeals regarding the date petitioners entered the disputed property. A secondary issue is whether a claim of a preferential right to acquire the property is a valid defense in a forcible entry case.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. On the first issue, the Court reiterated the settled doctrine that factual findings of the Court of Appeals are binding and conclusive on the Supreme Court. Exceptions to this rule, such as conclusions based on speculation or a lack of supporting evidence, were found inapplicable. The appellate court’s finding that petitioners entered the lot only in May 1963—after Carillo’s award and possession—was supported by testimonial and documentary evidence. The Court refused to consider new documents submitted by petitioners for the first time on appeal, as these were not presented during trial and private respondent was deprived of the opportunity to examine their materiality and genuineness.
On the second issue, the Court ruled that any claim of a preferential right to acquire the lot from the PHHC is irrelevant and immaterial in a summary action for forcible entry. The sole question in such a proceeding is prior physical possession and the deprivation thereof through force, intimidation, threat, strategy, or stealth. Title or ownership is not in issue. Since the courts uniformly found that Carillo had prior possession and was unlawfully deprived thereof by petitioners’ entry and construction, his right to be restored to possession is clear. No one may take the law into their own hands; the proper recourse for petitioners, if they have any superior claim of title, is a separate plenary action. The ejectment order was therefore upheld.