G.R. No. L-35621 July 30, 1976
Republic of the Philippines, represented by Francisco F. Saguiguit, in his capacity as Commissioner of the Agricultural Productivity Commission, petitioner, vs. Hon. Alejandro E. Sebastian, Judge of the Court of First Instance of Davao del Norte, and Mayor Gelacio Gementiza and Municipal Council of Tagum, Davao del Norte and all persons acting upon their orders, respondents.

FACTS

The Republic, through the Agricultural Productivity Commission (APC), filed a complaint for injunction with the Court of First Instance (CFI) of Davao del Norte against the Municipal Mayor and Council of Tagum. The APC alleged it was the rightful occupant and administrator of a 74,527-square-meter public land used as an agricultural demonstration station and nursery since 1938. The complaint sought to nullify Municipal Resolution No. 78, which approved the partition and segregation of the land for other government purposes, and to enjoin the municipal officials from bulldozing and developing the area. The Republic argued the resolution was enacted without jurisdiction, would destroy the nursery, and frustrate a significant public need for agricultural development.
The respondents moved to dismiss the complaint, contending the petitioner lacked capacity to sue and the court had no jurisdiction over the subject matter. The respondent Judge granted the motion, ruling that the action was essentially one for forcible entry over which the CFI had no original jurisdiction. The court held that the complaint’s core objective was to recover possession of the land, thereby falling under the summary ejectment proceedings of Rule 70, which is within the exclusive original jurisdiction of the municipal court.

ISSUE

Whether the Court of First Instance correctly dismissed the complaint for lack of jurisdiction on the ground that it was actually an action for forcible entry.

RULING

No, the Supreme Court reversed the order of dismissal and remanded the case for further proceedings. The Court held that the CFI had jurisdiction because the action was not one for forcible entry but a suit for prohibition and injunction. The legal logic is clear: the nature of an action is determined by the allegations in the complaint and the relief sought. The petitioner did not allege prior physical possession that was recently and forcibly deprived by the respondents—a requisite for a forcible entry case. Instead, the complaint sought to annul a municipal resolution as void for having been enacted without jurisdiction and to restrain acts pursuant to that resolution. The primary relief was the judicial declaration of the resolution’s nullity and the prevention of its enforcement, which inherently involved a matter not capable of pecuniary estimation. Such an action falls within the exclusive original jurisdiction of the CFI. The incidental prayer for restoration of possession was a consequence of the main action to prohibit unlawful acts, not an independent claim for recovery of possession. Therefore, the lower court erred in characterizing the suit as a mere possessory action and in dismissing it for lack of jurisdiction.