G.R. No. L-35482 April 30, 1987
MANUEL DRILON, petitioner, vs. LUIS GAURANA and Honorable VALERIO ROVIRA, as Judge of the Court of First Instance of Iloilo, Branch IV, respondents.

FACTS

Manuel Drilon held a free patent and an Original Certificate of Title for a parcel of agricultural land. Respondent Luis Gaurana filed two successive cases against Drilon concerning this same property. First, on September 4, 1970, Gaurana initiated an action for “Annulment of Free Patent and/or Reconveyance” before the Court of First Instance (CFI) of Iloilo (Civil Case No. 8323), directly challenging Drilon’s ownership title. Subsequently, on September 14, 1970, Gaurana filed a complaint for “Forcible Entry” before the Municipal Court of Nueva Valencia (MC Civil Case No. 126), alleging that Drilon had unlawfully taken possession of a portion of the land on July 14, 1970.
Drilon moved to dismiss the forcible entry case, arguing that the Municipal Court lacked jurisdiction because the real issue was ownership, not mere possession, and that the action constituted a splitting of a single cause of action, as the CFI case was already pending. The Municipal Court denied the motion, proceeded to trial, and rendered a judgment of ejectment against Drilon, who had been declared in default. Drilon then filed a petition for certiorari with the CFI, assailing the Municipal Court’s jurisdiction, but the CFI denied his petition. Drilon elevated the case to the Supreme Court.

ISSUE

The primary issue is whether the Municipal Court validly retained jurisdiction over the forcible entry case despite the pendency of the CFI action for annulment of title/reconveyance involving the same property.

RULING

The Supreme Court dismissed the petition and affirmed the lower court’s decision, upholding the Municipal Court’s jurisdiction. The legal logic rests on the fundamental distinction between the causes of action in an ejectment suit and an action involving title. Jurisdiction over ejectment cases is determined by the allegations in the complaint. Gaurana’s forcible entry complaint expressly alleged a recent act of dispossession (July 14, 1970) through force and strategy, which is sufficient to confer jurisdiction upon the inferior court. The Court emphasized that jurisdiction is based on the complaint’s allegations, not on the defenses raised in a motion to dismiss or answer.
The Court ruled there was no splitting of a single cause of action because the two cases asserted distinct legal rights. The forcible entry case concerned the issue of prior physical possession (possession de facto) and the legality of the method of dispossession, which is a question of maintaining public order. Conversely, the CFI case addressed the superior right of ownership (title), a question of ultimate legal title. Following precedent, the Court held that an inferior court is not divested of jurisdiction over an ejectment case simply because the defendant asserts a claim of ownership. The pendency of the ownership suit does not preclude the simultaneous resolution of the possessory issue, as the rights involved and the reliefs sought are separate and distinct.