De Guzman v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents filed an ejectment case against petitioner, alleging that petitioner unlawfully constructed a house on their lot in 1986 through stealth. Petitioner failed to file an answer after summons was served on her daughter. A judgment by default was rendered, ordering petitioner to vacate and pay attorney's fees. Procedural History: Petitioner filed a Petition for Relief from Judgment with the Regional Trial Court (RTC), arguing improper service of summons and prescription of the forcible entry action. The RTC ruled that summons was improperly served and the action was filed out of time, but it also received evidence on ownership and ordered petitioner to vacate, finding private respondents to be owners. The Petition: The Court of Appeals (CA) affirmed the RTC decision, holding that petitioner chose the wrong remedy (petition for relief instead of appeal) and failed to prove her right to possess. The CA also sustained the RTC's ruling on ownership and possession. Petitioner appealed to the Supreme Court.
Issue(s)
Whether the Regional Trial Court erred in not dismissing the forcible entry case after declaring it filed out of time and the Municipal Trial Court without jurisdiction. Whether the Court of Appeals erred in affirming the Regional Trial Court's decision on the matter of possession over the subject property. Whether the petitioner was denied due process due to improper service of summons.
Ruling
The Supreme Court set aside the decision of the Court of Appeals and ordered the dismissal of the Complaint filed in the Municipal Trial Court. The Court found that petitioner was denied due process due to improper service of summons and that the forcible entry action had prescribed.
Ratio Decidendi
On the prescription of the forcible entry action and the proper remedy after prescription: The Court held that it is indubitable on the face of the Complaint for forcible entry that the action had already prescribed. The Complaint alleged that petitioner entered the property by stealth sometime in 1986, and it was filed on April 15, 1988. The Court reiterated its ruling that forcible entry and unlawful detainer are quieting processes, and the one-year time bar to the suit is in pursuance of their summary nature. This one-year period is counted from the time the entry by stealth was made by the defendant. Since the complaint was filed more than one year after the alleged entry, the action had prescribed. The Court clarified that after the lapse of the one-year period for forcible entry, the remedy of the party dispossessed of a land is to file an "accion publiciana." Consequently, the respondent court committed reversible error when it sustained the ruling of the Regional Trial Court upholding the claim of ownership of the private respondents in an action that should have been dismissed for prescription and lack of jurisdiction over the person. The provided text does not contain a ratio decidendi that directly addresses whether the Court of Appeals erred in affirming the Regional Trial Court's decision on the matter of possession over the subject property. Therefore, I cannot provide a corresponding ratio for this issue. On the denial of due process and improper service of summons: The Court found that petitioner was indeed denied due process because she was not properly summoned before the Municipal Trial Court rendered judgment against her. The RTC correctly noted that for substituted service of summons to be valid, there must be a prior showing of the impossibility of personal service, which should be explained in the proof of service. The sheriff's resort to substituted service without such effort renders the service defective.
Main Doctrine
A forcible entry case filed more than one year after the alleged entry by stealth has prescribed, and the proper remedy thereafter is an 'accion publiciana'. Furthermore, substituted service of summons requires a prior showing of impossibility of personal service.