SAMPAYANG v CA

Facts:

Siblings Crispulo Vasquez and Florencia Vasquez-Gilsano filed a complaint for forcible entry against
Cesar Sampayan. They alleged that their mother (Cristina Quita) was the owner and actual possessor of
the subject land; that after their mothers death, they became co-owners pro-indiviso and lawful
possessor of the subject land; that while they were temporarily absent from the subject land, Sampayan,
through strategy and stealth, entered the lot and built a house thereon; and that despite their repeated
demands for Sampayan to vacate the same, Sampayan failed and refused to do so. On the other hand,
Sampayan contended that neither the siblings nor their mother have been in possession of the subject
land; and that he did not enter the subject land by stealth or strategy since he asked and was given
permission by the overseer of the lots true owners.

The MCTC presiding judge personally conducted an ocular inspection. After which, he ruled in favor
of Sampayan and against the Vasquez siblings, ruling that the proper remedy is an accion publiciana. The
RTC reversed the decision of MCTC, and the same was affirmed by the CA, both courts ruling that Quita
was in actual prior physical possession of the subject lot.

On appeal before the SC, Sampayang contends that he had sufficiently proven his prior physical
possession of the subject lot; that the proper remedy available to the Vasquez siblings is accion publiciana
which falls under the jurisdiction of the RTC and not of MCTC.

Issue:

Whether or not the MCTC had jurisdiction over the complaint?

Held:

Yes.

Ruling:

For the MCTC to acquire jurisdiction over a forcible entry case, it is enough that the complaint
avers the jurisdictional facts: (a) that the plaintiff had prior physical possession; and (b) that he was
deprived thereof by the defendant through force, intimidation, threats, strategy, and stealth.

In this case, the complaint makes such an averment. Therefore, it is immaterial that the evidence
adduced during the hearing rendered improper an action for forcible entry as it cannot deprive the MCTC
of its jurisdiction.

Issue:

Whether or not Sampayang has prior physical possession of the subject land?

Held:

Yes.

Ruling:

The improvements the MCTC judge saw in the premises could never have been introduced by the
Vasquez siblings nor by their mother. The findings in the ocular inspection have confirmed the allegation
of Sampayang that his predecessors-in-interest have introduced improvements (house, 5 coconut trees,
and 3 star apple trees) . Nothing can be seen on the land that on the land that the Vasquez siblings had
once upon a time been in possession of the land. From the appearance of the improvements introduced by
the predecessors-in-interest of Sampayang, it is showed that they have been in possession of the land for
more than one year.