Cajayon v. Batuyong
REITERATIONFacts
The Antecedents: Petitioners Flaviana Lim Cajayon and Carmelita Lim Constantino, along with Isagani P. Candelaria, were co-owners of a lot. They executed a partition agreement where petitioners received Lot 6-B (160 sqm) and Candelaria received Lot 6-A (100 sqm). Candelaria sold his lot, including improvements, to respondents Spouses Santiago and Fortunata Batuyong. Petitioners commenced construction of a seven-door bungalow building, which allegedly intruded into respondents' lot. Following a barangay meeting, petitioners agreed to defer construction pending a relocation survey. A verification survey by Geodetic Engineer Florentina C. Valencia revealed that petitioners' construction intruded into respondents' lot by approximately 20.61 square meters, including a right of way. Despite this delineation and demands to vacate, petitioners refused. Procedural History: Respondents filed an ejectment case before the Metropolitan Trial Court (MeTC). The MeTC ruled in favor of respondents, ordering petitioners to vacate the encroached portion and pay monthly rentals, attorney's fees, and costs. The Regional Trial Court (RTC) affirmed the MeTC decision, rejecting petitioners' arguments on jurisdiction, sufficiency of the complaint, and validity of the survey. The Court of Appeals (CA) dismissed petitioners' petition for review, holding that the MeTC had jurisdiction over the unlawful detainer case and affirming the findings on encroachment and the validity of the survey. The CA denied petitioners' motion for reconsideration. The Petition: Petitioners sought review of the CA rulings, primarily questioning the jurisdiction of the lower courts and the evidentiary weight of the verification survey. They argued that their entry was not by force, intimidation, threat, strategy, or stealth, nor by tolerance, thus not constituting unlawful detainer. They also contended that the action was filed beyond the one-year prescriptive period for forcible entry.
Issue(s)
Whether the Metropolitan Trial Court has jurisdiction over the ejectment case filed by the respondents. Whether the complaint sufficiently alleges a case for unlawful detainer or forcible entry. Whether the petitioners' entry into the disputed portion of the lot was by force, intimidation, threat, strategy, or stealth, or by tolerance, and whether the action was filed within the one-year prescriptive period for forcible entry. Whether the petitioners were builders in good faith. Whether the verification survey report has sufficient evidentiary weight.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the Metropolitan Trial Court has jurisdiction over the ejectment case, finding that the allegations in the complaint sufficiently established a case for forcible entry, which was filed within the one-year prescriptive period. The Court also ruled that petitioners were not builders in good faith and upheld the evidentiary weight of the verification survey report.
Ratio Decidendi
On the Jurisdiction of the Metropolitan Trial Court: The Court reiterated that the jurisdiction of the court in ejectment cases is determined by the allegations in the complaint and the relief sought. It clarified the distinctions between forcible entry and unlawful detainer. Forcible entry requires proof of prior physical possession and dispossession by force, intimidation, threat, strategy, or stealth, with the action to be filed within one year from the date of actual entry. Unlawful detainer, conversely, does not require prior possession by the plaintiff but requires that the defendant's possession was initially lawful (e.g., by contract or tolerance) and became illegal upon termination of the right to possess, with the action to be filed within one year from the last demand or notice to vacate. The Court found that the allegations in the complaint, particularly the petitioners' intrusion into respondents' property and refusal to vacate despite demands, sufficiently established a case for forcible entry, thus falling within the MeTC's jurisdiction. On the Nature of the Entry and Sufficiency of the Complaint: The Court found that the petitioners' entry into the disputed portion of the respondents' lot, characterized by their encroachment and refusal to vacate despite knowledge of the boundaries and objections from the respondents, constituted "force" within the meaning of the law on forcible entry. On the Prescriptive Period: The complaint alleged that petitioners started construction on May 21, 1996, and the ejectment suit was filed on April 11, 1997. This falls within the one-year prescriptive period for forcible entry cases, counted from the date of actual entry. Therefore, the action was not barred by prescription. On the Status of Builders in Good Faith: The Court rejected the petitioners' claim of being builders in good faith. Good faith, in this context, requires the belief that the land being built upon is one's own and ignorance of any defect in the title. The Court emphasized that once the verification survey report became known to the petitioners, confirming their encroachment on respondents' titled property, their good faith ceased. Possession adverse to a registered owner is necessarily tainted with bad faith. Proceeding with construction despite knowledge of respondents' ownership placed petitioners in bad faith. On the Evidentiary Weight of the Verification Survey: The Court held that petitioners' challenge to the evidentiary weight of the verification survey report was essentially a request to re-examine factual findings, which is beyond the Supreme Court's scope in a petition for review on certiorari. The Court noted that the survey was conducted by a government geodetic engineer, raising a presumption of regularity in the performance of official duty. Furthermore, the records indicated that the survey was conducted with the agreement and presence of both parties, a finding affirmed by the lower courts and the Court of Appeals. Thus, the survey report was accorded due evidentiary weight.
Main Doctrine
The Supreme Court reiterated that the jurisdiction of the court in ejectment cases is determined by the allegations of the complaint and the character of the relief sought. It clarified that an action for unlawful detainer requires prior physical possession by the plaintiff and subsequent dispossession by the defendant due to termination of the right to possess, while forcible entry involves unlawful entry from the beginning by force, intimidation, threat, strategy, or stealth. The Court also emphasized that possession adverse to a titled owner is necessarily in bad faith, and factual findings of lower courts, especially when affirmed by the Court of Appeals, are generally binding on the Supreme Court.