Balibago Faith Baptist Church v. Faith in Christ Jesus Baptist Church

Summary

This Supreme Court case involved a dispute between two Baptist churches over property possession in Angeles City. BFBC and PBSBC filed an unlawful detainer complaint against FCJBC and Galvan, seeking to eject them from church property. The MTC and RTC ruled in favor of BFBC, but the Court of Appeals reversed, dismissing the complaint. The Supreme Court affirmed the dismissal, holding that the complaint failed to properly allege facts constituting either unlawful detainer or forcible entry. The Court found that FCJBC's possession appeared unlawful from the beginning without contractual basis or tolerance, but the complaint failed to specify how and when dispossession occurred. Since procedural requirements under Rule 70 were not satisfied, the MTC lacked jurisdiction, and a plenary action in the RTC was the proper remedy. The decision clarifies jurisdictional requirements for ejectment cases and the distinction between unlawful detainer and forcible entry.