1. Hilario vs.

Salvador
A dispute over land possession in Romblon, Philippines leads to a jurisdictional issue,
resulting in the nullification of all proceedings and the dismissal of the complaint.

Facts:

● The case involves a dispute over the possession of a parcel of land in Romblon,
Philippines.
● The petitioners, Cesar T. Hilario and his siblings, filed a complaint against Allan T.
Salvador in the Regional Trial Court (RTC) of Romblon.
● The petitioners alleged that they are co-owners of the land and that Salvador
constructed a dwelling unit on the property without their knowledge.
● The petitioners demanded that Salvador vacate the premises and pay damages.

Issue:

● Whether the RTC had jurisdiction over the case.

Ruling:

● The Supreme Court affirmed the decision of the Court of Appeals (CA) and held
that the RTC had no jurisdiction over the case.
● All the proceedings in the RTC, including the decision, were null and void.
● The complaint was dismissed.

Ratio:

● The main issue before the Supreme Court was whether the RTC had jurisdiction
over the action.
● The petitioners argued that the action was an accion reivindicatoria, which is
incapable of pecuniary estimation and falls within the jurisdiction of the RTC.
● The Supreme Court disagreed and held that the action was an accion publiciana,
or one for the recovery of possession of the property.
● An accion reivindicatoria involves the recovery of ownership and possession
based on ownership, while an accion publiciana is a suit for the recovery of
possession of the right to possess.
● The jurisdiction of the court over an action involving title to or possession of land
is determined by the assessed value of the property.
● Since the complaint did not contain an allegation of the assessed value of the
property, it could not be determined whether the RTC or the Municipal Trial Court
(MTC) had jurisdiction.
● The Court noted that during trial, the petitioners presented a tax declaration
showing an assessed value of P5,950.00 in 1991, but they did not present the
tax declaration when they filed the complaint in 1996.
● Therefore, even if the assessed value was the same in 1995 or 1996, the MTC
would have had jurisdiction because the assessed value was less than
P20,000.00.
 2. Peralta-Labrador vs. Bugarin
A widow seeks to recover possession and ownership of a lot from a man who forcibly
took possession, but the Supreme Court rules that the lower court had no jurisdiction
over the case due to the expiration of the cause of action for forcible entry, resulting in
the dismissal of the complaint.

Facts:

● Petitioner Lilia V. Peralta-Labrador filed a case for "Recovery of Possession and

Ownership" against respondent Silverio Bugarin in the Municipal Trial Court
(MTC) of San Felipe, Zambales.
● Petitioner alleged that she purchased the lot in 1976 and had been in prior
physical possession of it until respondent forcibly took possession of a portion of
the lot in 1994.
● Petitioner claimed that the cause of action for forcible entry had prescribed, and
the MTC had no jurisdiction over the case.

Issue:

● Whether the MTC had jurisdiction over the case considering the expiration of the
cause of action for forcible entry.

Ruling:

● The Supreme Court ruled that the MTC had no jurisdiction over the case due to
the expiration of the cause of action for forcible entry.
● The Court explained that an action for forcible entry is a summary and quieting
process, and the one-year time bar for filing a suit is in line with the summary
nature of the action.
● In this case, petitioner alleged prior physical possession of the lot in 1976 and the
forcible entry by respondent two years prior to the filing of the complaint in 1996.
● Since the cause of action for forcible entry had prescribed, the case should have
been filed with the Regional Trial Court (RTC) as an accion publiciana or an
accion reivindicatoria.
 ● The Court emphasized that jurisdiction over the subject matter cannot be waived
by the parties or cured by their silence or consent.

Ratio:

● Jurisdiction of a court is determined by the allegations in the complaint.

● In ascertaining whether the action falls within the exclusive jurisdiction of the
inferior courts, the averments of the complaint and the relief sought are
examined.
● In this case, petitioner's complaint alleged prior physical possession and forcible
entry, which constituted a case for forcible entry.
● However, since the unlawful possession occurred two years prior to the filing of
the complaint, the cause of action for forcible entry had prescribed.
● Therefore, the MTC had no jurisdiction over the case, and it should have been
filed with the RTC.
● The Court also emphasized that lack of jurisdiction over the subject matter
cannot be waived by the parties or cured by their silence or consent.
● Additionally, the Court found that petitioner failed to prove that the disputed
portion of the lot was part of her property, and respondent failed to present
evidence conclusively showing ownership.
● Thus, the complaint was dismissed.
 3. Rivera-Calingasan vs. Rivera

A dispute over possession of a property in Lipa City, Batangas leads to a legal battle
between the heirs of the deceased owner and a claimant who renounced his
usufructuary rights, resulting in the Supreme Court affirming the decision in favor of the
heirs but awarding compensation to the claimant's estate.

Facts:

● The case involves a dispute over the possession of a property in Lipa City,
Batangas.
● The Court of Appeals affirmed with modification the decision of the Regional Trial
Court (RTC) in favor of the heirs of the deceased owner, Wilfredo Rivera, but
awarded compensation to the claimant, Evangeline Rivera-Calingasan.
● Wilfredo Rivera and his wife, Loreto Inciong, acquired several parcels of land in
Lipa City.
● After Loreto's death, an extrajudicial settlement was executed by her heirs,
adjudicating the properties in favor of Evangeline and her sister.
● Wilfredo waived his rights to the properties but retained his usufructuary rights.
● The Register of Deeds cancelled the old titles and issued new ones in the names
of Evangeline and her sister with an annotation of Wilfredo's usufructuary rights.
● Almost a decade later, Wilfredo filed a complaint for forcible entry against
Evangeline and Star Honda, Inc., claiming that they unlawfully took possession of
the property.
● The Municipal Trial Court dismissed the complaint, finding no evidence of
Wilfredo's prior possession.
● Wilfredo appealed to the RTC, which affirmed the dismissal.
● However, upon reconsideration, the RTC ordered the eviction of the petitioners.
● The CA affirmed the RTC's findings, noting that Evangeline's admission of a
different residence rendered her claim of possession improbable.
● The CA also deleted the award of attorney's fees.
● The petitioners then filed a petition for review with the Supreme Court.

Issue:

● Who had prior physical possession of the property?

Ruling:

● The Supreme Court ruled that possession in ejectment cases means actual
physical possession, regardless of the nature of possession or ownership.
● The respondents, Wilfredo's heirs, were able to prove prior physical possession
through various evidence, including Evangeline's admission of a different
residence and the affidavit of the Barangay Captain attesting to Wilfredo's prior
possession.
● The ejectment case was not extinguished by Wilfredo's death, as it is a real
action that can be enforced by or against the heirs.
● The usufructuary rights held by Wilfredo were rendered moot by his death.
● The Court affirmed the award of compensation for the use and occupation of the
property, which will be distributed to Wilfredo's heirs.

Ratio:

● Possession in ejectment cases means actual physical possession, regardless of

the nature of possession or ownership.
● The respondents were able to prove prior physical possession through various
evidence, including Evangeline's admission of a different residence and the
affidavit of the Barangay Captain attesting to Wilfredo's prior possession.
● The ejectment case was not extinguished by Wilfredo's death, as it is a real
action that can be enforced by or against the heirs.
● The usufructuary rights held by Wilfredo were rendered moot by his death.
● Compensation for the use and occupation of the property was awarded and will
be distributed to Wilfredo's heirs.

Conclusion:

● The Supreme Court denied the appeal and affirmed the decision of the Court of
Appeals with modification.
● The issue of restitution of possession was rendered moot by Wilfredo's death, but
the monetary award for compensation for the use and occupation of the property
was upheld and will be distributed to Wilfredo's heirs.
● The case was remanded to the RTC for the computation and execution of the
total amount due.
 4. Santos vs. Spouses Ayon
Ruben Santos files a complaint for illegal detainer against the Ayon spouses who refuse
to vacate his property, leading to a jurisdictional dispute over whether the case should
be heard in the Municipal Trial Court or the Regional Trial Court.

Facts:

● Ruben Santos filed a complaint for illegal detainer against the Ayon spouses who
refused to vacate his property in Davao City.
● Santos informed the Ayons in 1985 that the building on his property occupied a
portion of his land, but he allowed them to continue using it.
● In 1996, Santos needed the entire portion of his lot and demanded that the
Ayons demolish and remove the encroaching part of the building and turn over
possession to him.
● The dispute was referred to the barangay lupon, but no settlement was reached.
● Santos then filed a complaint for illegal detainer.

Issue:

● Whether the Court of Appeals committed an error in holding that Santos'

complaint should have been an accion publiciana before the Regional Trial Court
(RTC) instead of an action for unlawful detainer before the Municipal Trial Court
in Cities (MTCC).

Ruling:

● The Supreme Court ruled in favor of Santos and reinstated the decision of the
MTCC.
● The Court held that Santos' complaint for unlawful detainer was properly within
the jurisdiction of the MTCC.
● The Court emphasized that possession by tolerance is lawful, but it becomes
unlawful when the possessor refuses to vacate upon the owner's demand.
● Santos' cause of action for unlawful detainer stemmed from the Ayons' failure to
vacate the premises upon his demand in 1996.
● Therefore, the MTCC had jurisdiction over the case.
Ratio:

● The Court based its decision on Section 1 of Rule 70 of the Rules of Court, which
states that all actions for forcible entry or unlawful detainer shall be filed with the
proper Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit
Trial Courts.
● The Court clarified that even if the defendant raises the question of ownership in
his pleadings, the said courts are not divested of jurisdiction over the case.
● The Court also explained that there are two distinct causes of action: forcible
entry and unlawful detainer.
● In this case, Santos' complaint for unlawful detainer was proper because the
Ayons' possession of the property was initially lawful by virtue of tolerance but
became illegal when they continued their possession despite Santos' demand.
 5. Ross Rica Sales Center Inc. vs. Spouses Ong
The Supreme Court ruled in favor of the petitioners in the case of Ross Rica Sales
Center Inc. v. Spouses Ong, stating that the Municipal Trial Court had jurisdiction over
the ejectment case and the issue of ownership was not essential in an unlawful detainer
case.

Facts:

● Ross Rica Sales Center, Inc. and Juanito King & Sons, Inc. (petitioners) filed a
complaint for ejectment against spouses Gerry Ong and Elizabeth Ong
(respondents).
● The complaint alleges that the petitioners are the registered owners of three
parcels of land and that the respondents, the former owners, are unlawfully
withholding possession of the lots.
● The Municipal Trial Court (MTC) and the Regional Trial Court (RTC) both ruled in
favor of the petitioners.
● However, the Court of Appeals reversed the decision, stating that the MTC did
not have jurisdiction over the case.

Issue:

● Whether the RTC decision has already become final and executory at the time
the petition for review was filed.
● Whether the allegations in the complaint constitute a case for unlawful detainer
properly cognizable by the MTC.
● Whether the petitioners, as registered owners, are entitled to the possession of
the subject premises.

Ruling:

● The Supreme Court ruled in favor of the petitioners.

● The filing of a Motion for Reconsideration by the respondents effectively withdrew
their defective Notice of Appeal, thereby tolling the period of appeal.
 ● The allegations in the complaint, which stated that respondents were unlawfully
withholding possession from the petitioners, were sufficient to constitute a case
for unlawful detainer.
● The issue of ownership is generally unessential in an unlawful detainer case, and
the MTC had jurisdiction to try the ejectment case.
● The pending actions for declaration of nullity of deed of sale and transfer
certificate of title and quieting of title in another case will not abate the ejectment
case, as the issue of ownership cannot be subject to collateral attack.

Ratio:

● The filing of a Motion for Reconsideration effectively withdrew the defective

Notice of Appeal, tolling the period of appeal and allowing the RTC decision to
still be reviewed.
● The allegations in the complaint, stating that respondents were unlawfully
withholding possession, were sufficient to constitute a case for unlawful detainer.
● The issue of ownership is not essential in an unlawful detainer case, and the
MTC had jurisdiction to try the ejectment case.
● The pending actions for declaration of nullity of deed of sale and transfer
certificate of title will not affect the ejectment case, as the issue of ownership
cannot be subject to collateral attack.

Conclusion:

● The Supreme Court reversed the decision of the Court of Appeals and reinstated
the judgment of the lower courts.
● The MTC had jurisdiction over the ejectment case, and the allegations in the
complaint were sufficient to constitute a case for unlawful detainer.
● The issue of ownership is not essential in an unlawful detainer case, and the
pending actions for declaration of nullity of deed of sale and transfer certificate of
title will not affect the ejectment case.