Peralta-Labrador v. Bugarin
REITERATIONFacts
The Antecedents: Petitioner Lilia V. Peralta-Labrador filed a case for Recovery of Possession and Ownership over Cadastral Lot No. 2650, specifically a 108 sq. m. portion, alleging she purchased the lot in 1976 and was issued a tax declaration. In 1990, a road construction traversed her lot, segregating the 108 sq. m. portion. In 1994, respondent Silverio Bugarin forcibly took possession of this segregated portion and refused to vacate. Procedural History: Petitioner filed a complaint for recovery of possession and ownership with the Municipal Trial Court (MTC) on January 18, 1996. The MTC ruled in favor of the respondent, declaring him owner based on an Original Certificate of Title (OCT) No. P-13011 and dismissing petitioner's complaint. The Regional Trial Court (RTC) affirmed the MTC decision. The Court of Appeals (CA) modified the RTC decision by deleting the declaration of ownership and monetary awards, but affirmed the dismissal of the complaint, noting that the OCT was not formally offered in evidence. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for review on certiorari before the Supreme Court, challenging the CA's decision.
Issue(s)
Whether the MTC had jurisdiction over the forcible entry case filed by the petitioner. Whether the petitioner sufficiently proved her ownership and prior physical possession of the disputed lot.
Ruling
The Supreme Court annulled and set aside the decisions of the MTC, RTC, and CA for lack of jurisdiction and dismissed the petitioner's complaint. The Court ruled that the MTC did not have jurisdiction over the case because the cause of action for forcible entry had prescribed.
Ratio Decidendi
On the issue of MTC jurisdiction: The Court held that the petitioner's complaint alleged forcible entry occurring "two years" prior to the filing of the complaint on January 18, 1996. According to Section 1, Rule 70 of the Revised Rules of Civil Procedure, an action for forcible entry must be instituted within one year from the date of unlawful deprivation or withholding of possession. Since the alleged dispossession occurred more than one year before the filing of the case, the MTC lacked jurisdiction to entertain the forcible entry complaint. The Court reiterated that after the lapse of the one-year period, the proper actions to recover possession are accion publiciana (a suit for recovery of the right to possess) or accion reivindicatoria (an action to recover ownership as well as possession), which should be filed before the Regional Trial Court (RTC). The Court emphasized that jurisdiction over the subject matter cannot be waived by the parties or cured by their silence, acquiescence, or even express consent, and a party may assail the jurisdiction of the court at any stage of the proceedings, even on appeal. The failure of the respondent to insist on the defenses of lack of cause of action and prescription in his amended answer did not vest the MTC with jurisdiction. On the issue of petitioner's proof of ownership and possession: Even if the MTC had jurisdiction, the Court found that the petitioner failed to prove her ownership and prior physical possession of the controverted 108 sq. m. lot. The petitioner admitted she had never seen the Cadastral Map of San Felipe, Zambales, and relied only on a Survey Notification Card which did not reflect the disputed lot. She also failed to cause a survey of Cadastral Lot No. 2650 after the road construction to prove that the segregated portion was part thereof. The Court applied the principle of ei incumbit probotio qui dicit, non qui negat, meaning he who asserts, not he who denies, must prove. Furthermore, the Court noted that ownership could not be awarded to the respondent because OCT No. P-13011 and the Survey Plan were not formally offered in evidence, thus they could not be considered by the court, even though ownership may be passed upon in ejectment cases for the sole purpose of determining the nature of possession.
Main Doctrine
A Municipal Trial Court (MTC) lacks jurisdiction over a forcible entry case if the complaint alleges that the unlawful deprivation or withholding of possession occurred more than one year prior to the filing of the suit, as the cause of action has prescribed. Such a case should be filed before the Regional Trial Court (RTC) as an accion publiciana or accion reivindicatoria.