Cesar Sampayan, petitioner vs.

Crispulo Vasquez and Florencia VasquezGalisano, respondents

GR No. 156360, 14 January 2005
DOCTRINES
Remedial Law, Jurisdiction of MeTC/MCTC/MCTC: The averment of
jurisdictional facts in a forcible entry case, that the plaintiff had prior physical
possession (of the property) and that he/she was deprived of it through force,
intimidation, threats, strategy, and stealth is enough for the said court to
acquire jurisdiction over the case.
Civil Law (Property and Land Titles) Oppositors in cadastral cases: An
opposition of an oppositor in a cadastral case is not by itself, establishes prior
physical possession because not all oppositors in cadastral cases are actual
possessors of the land subject of the proceeding.
FACTS
Respondents-siblings Crispulo and Florencia Vasquez-Galisano filed forcible
entry case against petitioner Cesar Sampayan in the MCTC of Bayugan and
Sibagat, Agusan del Sur. They allege that Sampayan entered Lot No. 1859 PLS225 and built a house there without their knowledge, consent, or authority,
supposedly effected through stealth and strategy.
Moreover, they alleged that their mother Cristita Quita was the actual
possessor of the said lot and after her death, they became the lands lawful
possessor. On 1 June 1997, Cesar entered the lot through strategy and strategy
and subsequently built a house there. However, despite their repeated
demands, Cesar refused to vacate and surrender the disputed lot.
Petitioner Sampayan denied all allegations against him and averred that he
does not know the Vasquez siblings (their identity or place of residence). He
also stated that he was given permission to enter and occupy the lot by Maria
Ybaez, the overseer of the lands true owners Mrs. and Mr. Anastacio
Terradios.

/archie.manansala
CEU Law, Property, SY 2015-2016

The respondents-siblings presented evidence such as Cristitas death

certificate, Tax Declaration over the lot in her name, as well as a document
stating that the lot was subject of a cadastral proceeding where Cristita was
one of the oppositors.
The petitioner presented evidence stating his claim, including an affidavit of
Dionesia Noynay that since 1960s until the case was filed, neither Cristita nor
the respondents-siblings ever possessed the lot.
After presentation of evidence, the Bayugan-Sibagat MCTC dismissed the case
of the respondents Vasquez siblings against petitioner Cesar Sampayan.
The respondents-siblings appealed the dismissal of their case to the RTC Br.
VII of Agusan del Sur, where it reversed the MCTCs decision. The Court of
Appeals likewise affirmed the Agusan Del Sur RTCs decision. Sampayan asked
for reconsideration of the adverse decision by the Court of Appeals, but it was
denied.
ISSUES
Thus, petitioner Cesar Sampayan appealed the case to Supreme Court, raising
these issues:
1. Whether the respondents Vasquez siblings has a valid right to possess
and own the said lot
2. Can they institute forcible entry case against him?
HELD BY THE SUPREME COURT
Cesar Sampayans petition is GRANTED and the Court of Appeals decision
affirming the RTC Agusan del Surs judgment in favor of the Vasquez siblings is
REVERSED.
Right to possess the property: The Supreme Court held that Cristita Quita and
her children Florencia Vasquez-Galisano and Crispulo Vasquez failed to
establish valid possession in concept of an owner. It upheld the findings of the
MCTC and the affidavit of Dionesia Noynay that it was Sampayans
predecessors-in-interest the Occida spouses who introduced improvements in
the disputed lot and that they were not physically in possession of the disputed
property.
/archie.manansala
CEU Law, Property, SY 2015-2016

The contention of the respondents that Cristitas participation in a cadastral

proceeding vests valid possession as owner over the lot is also disagreed by the
Court.
Right to institute the forcible entry case: The Supreme Court denied the
petitioners contention that the MCTC of Sibagat-Bayugan did not acquire
jurisdiction over the forcible entry case filed against him by the respondentssiblings. Their allegation that he entered the lot without their consent,
knowledge, authority through force, stealth or strategy is enough to vest
jurisdiction of the said MCTC over the case.

/archie.manansala
CEU Law, Property, SY 2015-2016