Heirs of Aoas v. As-il
REITERATIONFacts
The Antecedents: Respondent Juliet As-il filed a complaint for forcible entry against petitioners Heirs of Johnny Aoas, claiming ownership and prior possession of a 42 square meter lot covered by TCT No. T-57645. She alleged that the Heirs of Aoas, by stealth and strategy, initiated digging, clearing, and construction of a house, dispossessing her of the property. Procedural History: The Municipal Trial Court (MTC) ruled in favor of As-il, ordering the Heirs of Aoas to vacate the 42 square meter portion, remove improvements, and pay compensation. The Regional Trial Court (RTC) initially affirmed the MTC decision but later reversed itself upon reconsideration, dismissing As-il's complaint based on a tax declaration showing the Heirs of Aoas' prior possession. The Court of Appeals (CA) reinstated the MTC decision, holding that the tax declaration was improperly considered for the first time on appeal. The Petition: The Heirs of Aoas filed a petition for review on certiorari, questioning the CA's decision to set aside the RTC's resolution and find them liable for forcible entry. They argued that the issue was a boundary dispute, not forcible entry, and that they had built their house within their titled property.
Issue(s)
Whether the Court of Appeals erred in setting aside the Resolution of the Regional Trial Court and finding the petitioners liable for forcible entry, considering the presence of a boundary dispute. Whether a boundary dispute involving overlapping titled properties can be resolved in a forcible entry case, and the proper action for resolving such disputes.
Ruling
The petition is meritorious. The September 17, 2014 Decision and June 8, 2015 Resolution of the Court of Appeals are REVERSED and SET ASIDE, without prejudice. The case is dismissed without prejudice to the proper filing of a case in the proper forum.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in finding the petitioners liable for forcible entry and whether a boundary dispute can be resolved in such a case: The Court held that the real issue presented by the case was not merely the right to possess the property, but a boundary dispute concerning an overlapping portion of land claimed by both parties under separate certificates of title. The MTC and RTC findings confirmed that the properties overlapped, and the core contention revolved around which titled land encroached upon the other. The CA erred in affirming the ejectment of the Heirs of Aoas, as the issue raised could not be properly ventilated in a forcible entry case. The Court reiterated the settled rule that a boundary dispute can only be resolved in an accion reivindicatoria, not in an ejectment case like forcible entry. Ejectment proceedings under Rule 70 are summary in nature and are limited to determining who has the better right of physical possession, not ownership or title. In forcible entry, the issue is who had prior de facto possession. Here, the dispute centered on encroachment, which requires a determination of title and boundaries, beyond the scope of a summary ejectment suit. The MTC, in passing upon the case, acted without authority as the case was beyond the ambit of a summary proceeding. All other issues need not be discussed as the remedy availed of by the parties was improper.
Main Doctrine
A boundary dispute, which involves determining encroachment and the respective rights of parties based on their certificates of title, cannot be resolved in an ejectment case (forcible entry or unlawful detainer) under Rule 70 of the Rules of Court, as such proceedings are summary in nature and limited to the issue of physical possession. The proper remedy for a boundary dispute is an accion reivindicatoria.