FACTS
The case arose from five consolidated complaints for forcible entry filed by Felomina Salamanca-Guzman, the Heirs of Flora Medriano Villasista, Erlinda Cariño, Vito Roldan, and Alejandro Collado before the Municipal Trial Court in Cities (MTCC), San Jose City. The respondents alleged that they owned adjoining parcels of land covered by Transfer Certificates of Title in Barangay Palestina, San Jose City, including portions formed through accretion. They claimed that in November 2013, Rolando Galindez, Daniel Liberato, and their companions unlawfully entered the accreted portions by means of force, strategy, or stealth, fenced the area, and cultivated it with onions. After barangay conciliation failed, they filed actions for forcible entry under Rule 70 of the Rules of Court, seeking restoration of possession.
The MTCC dismissed the complaints, holding that the respondents failed to prove prior physical possession, which is the essential element in forcible entry cases. The Regional Trial Court (RTC) affirmed the dismissal. On appeal, however, the Court of Appeals (CA) reversed the lower courts after considering additional evidence, including second Judicial Affidavits of barangay officials and a Supplemental Judicial Affidavit and Certification of a geodetic engineer that were either submitted after the MTCC had rendered judgment or presented for the first time on appeal. The CA concluded that respondents had sufficiently established prior possession and ordered petitioners to vacate the property.
Petitioners elevated the case to the Supreme Court under Rule 45 of the Rules of Court, arguing that the CA committed reversible error by admitting evidence not timely presented before the MTCC in violation of the Revised Rules on Summary Procedure. They likewise contended that respondents failed to establish by preponderance of evidence that they had prior physical possession of the disputed property, which is the controlling issue in forcible entry cases.
ISSUE
Whether the Court of Appeals erred in considering additional affidavits and documentary evidence that were submitted only after the MTCC had rendered its decision or were presented for the first time on appeal, contrary to the Revised Rules on Summary Procedure.
Whether respondents successfully proved, by preponderance of evidence, that they had prior physical possession of the disputed property, thereby entitling them to recovery of possession in an action for forcible entry under Rule 70 of the Rules of Court.
Whether the CA correctly reversed the factual findings of the MTCC and RTC despite the evidence on record.
HELD
The Supreme Court granted the petition, reversed the Court of Appeals, and reinstated the decisions of the MTCC and RTC dismissing the complaints for forcible entry. The Court held that forcible entry cases are governed by the Revised Rules on Summary Procedure, which require the parties to submit all affidavits, documentary evidence, and position papers within the period fixed by the court. Additional evidence may be received only when the trial court itself orders clarification of material facts. Consequently, the CA committed reversible error in considering the second Judicial Affidavits of the barangay officials and the Supplemental Judicial Affidavit and Certification of the geodetic engineer because these were presented only after the MTCC had already decided the case or for the first time on appeal. Allowing such piecemeal presentation of evidence would defeat the objective of summary proceedings, which is the speedy disposition of ejectment cases.
The Court further emphasized that under Rule 70 of the Rules of Court, the sole issue in forcible entry is prior physical or material possession (possession de facto), not ownership or title. Although respondents relied on their certificates of title and alleged accretion, ownership alone does not establish prior physical possession. Citing Section 1, Rule 133 of the Rules on Evidence, the Court explained that the party bearing the burden of proof must establish its claim by preponderance of evidence, meaning the greater weight of credible evidence. The respondents' testimonies consisted mainly of general assertions of possession and failed to demonstrate actual occupation of the disputed property before petitioners entered it.
On the other hand, the petitioners presented more credible and convincing evidence showing that they and their predecessor had been cultivating and possessing the disputed property for decades. Their evidence, including testimonies and affidavits properly presented before the MTCC, established continuous actual possession long before the filing of the complaints. The Court reiterated the settled rule that a plaintiff in an ejectment case must recover on the strength of his own evidence and not on the weakness of the defendant's case. Since respondents failed to prove prior physical possession by preponderance of evidence, they were not entitled to restoration of possession. Accordingly, the Supreme Court reinstated the MTCC and RTC decisions dismissing the complaints for forcible entry
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