G.R. No. L-19370; April 30, 1964
GENARO PRADO, plaintiff-appellant, vs. APOLINARIO CALPO, ET AL., defendants-appellees.

FACTS

Plaintiff Genaro Prado filed a forcible entry case in the Justice of the Peace (JP) Court of San Jacinto, Pangasinan, against defendants Apolinario Calpo and Dalmacio Cabrera. Defendants, in their Answer, asserted that Cabrera was the registered owner of the disputed land, holding Transfer Certificate of Title No. 23006, and contended the JP Court lacked jurisdiction as the case involved a question of title. The JP Court denied a motion to dismiss on this ground and, after trial, ruled in favor of Prado. It found he had prior physical possession and ordered defendants to vacate, pay damages, and restore possession. Defendants appealed to the Court of First Instance (CFI).
Upon appeal, defendants filed a Motion to Dismiss in the CFI, reiterating the jurisdictional issue. The CFI granted the motion, dismissing the case. It reasoned that the presentation of a certificate of title in the defendants’ name necessarily involved the issue of ownership, which the JP Court had no jurisdiction to adjudicate. The CFI held that possession is merely an attribute of ownership and the inferior court lost jurisdiction when evidence of ownership was introduced. Plaintiff moved for reconsideration, which was denied, prompting this appeal.

ISSUE

Whether the Court of First Instance erred in dismissing the forcible entry case on appeal, based on the ground that the JP Court lacked jurisdiction because the issue of ownership was involved.

RULING

Yes, the CFI committed reversible error. The Supreme Court set aside the CFI’s dismissal order and remanded the case for further proceedings. The legal logic is anchored on the distinct nature of forcible entry cases. The sole issue in such actions is prior physical possession, independent of any claim of ownership. Jurisdiction in forcible entry cases is conferred by law upon inferior courts based on the allegations of the complaint concerning possession de facto. The JP Court correctly exercised jurisdiction because Prado’s complaint alleged prior physical possession and subsequent deprivation by force, intimidation, threat, strategy, or stealth, which are the jurisdictional facts required under the rules.
The CFI erred in concluding that the introduction of a certificate of title automatically divested the JP Court of jurisdiction. The Supreme Court clarified that a forcible entry action can proceed even against the registered owner if the plaintiff can prove prior physical possession. The purpose of the action is to prevent breaches of the peace and provide a speedy remedy for the restoration of possession. Questions regarding the validity of title or ownership are irrelevant to the immediate issue of possession and must be ventilated in a separate action, such as one to quiet title. The CFI, on appeal, should have reviewed the case on its merits to determine the correctness of the JP Court’s factual findings on prior possession, not dismissed it based on an ancillary claim of ownership.