Jesus Dela Rosa v. Santiago Carlos

Summary

This forcible entry case involved a dispute over physical possession of a house and lot in Paombong, Bulacan. Spouses Dela Rosa claimed ownership through a 1966 deed of sale from Leonardo Carlos and alleged continuous possession despite residing in Manila, visiting only on weekends. Santiago Carlos and Teofila Pacheco, claiming to be Leonardo's heirs, argued the sale was invalid without spousal consent and that they had always occupied the property. The MTC and RTC ruled for the Spouses Dela Rosa, but the Court of Appeals reversed, finding insufficient proof of prior possession and invalid sale. The Supreme Court reinstated the lower courts' decisions, ruling that weekend visits and acts of dominion constitute actual possession, and that validity of the deed cannot be collaterally attacked in ejectment proceedings. The case established that physical presence on every part of property is not required for possession, and that ejectment cases determine physical possession independent of ownership issues.