G.R. No. 178907 - FLORA N. FLORES, REPRESENTED BY HER ATTORNEYS-IN-FACT, JOSE NAVARRO AND ERLINDA NAVARRO, VS. SPOUSES LUCAS AND ZENAIDA QUITALIG. D E C I S I O N - Supreme Court E-Library

Ruling

accordingly set aside that of the MTC. The RTC held that Flores was able to prove that she and her predecessors-in-interest have been in possession of the subject lot since 1950, through tax declarations under the names of her predecessors-in-interest. In stark contrast thereto, the RTC doubted the spouses Quitalig's claim of prior possession, because their documentary evidence to prove their prior possession over the subject property being dated 2004, at the earliest, was apparently prepared after the complaint was filed. The RTC also held that the issue on Flores' ownership cannot be properly appreciated in a case for forcible entry and should, therefore, be resolved in a separate action for the annulment of the adverted deed of sale. Aggrieved, the spouses Quitalig filed a petition for review with the Court of Appeals (CA), which, on January 31, 2007, rendered a Decision [3] ruling in favor of the spouses Quitalig. The CA ruled that Flores failed to sufficiently show that the subject lot is within the boundaries of her claimed property, Lot No. 4835. This failure, according to the CA, precluded it from properly determining whether or not there was forcible entry. Accordingly, the CA reversed the decision of the RTC and dismissed Flores' complaint for forcible entry. Flores accordingly moved for the reconsideration of the CA's decision but the same was denied in the CA's July 26, 2007 Resolution. Flores now comes before this Court setting forth this issue, summarized as follows: Whether the CA erred in holding that petitioner failed to present adequate proof to establish the identity of the subject lot and, thus, also failed to show that the subject lot is within the metes and bounds of her land, thereby precluding the CA from determining the issue of forcible entry. Flores maintains that she, her attorneys-in-fact, and her predecessors-in-interest have been in peaceful possession of the subject property since 1950 until the possession was interrupted by the spouses Quitalig in 2004 when they abruptly entered the property and fenced its perimeter. The spouses Quitalig, on the other hand, claim that the subject property belongs to them as it is part of the lot they had purchased from Cresencio and Jose Madayag in 1982 and had been in their possession ever since. The petition has merit. An action for forcible entry is summary in nature. It is designed to recover physical possession through prompt proceedings that are restrictive in nature, scope, and time limits. [4] In such action, the plaintiff must prove that he was in prior possession of the land or building and that he was deprived thereof by means of force, intimidation, threat, strategy, or stealth. [5] Owing to the summary nature of forcible entry cases, courts should expeditiously resolve the issue of possession, eschewing, as a rule, the issue of ownership since such cases proceed independently of any claim of ownership and the plaintiff needs merely to prove prior possession de facto a