Saclolo v. Intermediate Appellate Court

Summary

This case involves a jurisdictional dispute over an ejectment action filed by landowner Marte Saclolo against occupant Eleuterio Perea. Saclolo obtained title to land in 1979 and filed forcible entry/unlawful detainer against Perea, who claimed occupation since 1958. The Municipal Trial Court ruled for Saclolo, but the Regional Trial Court and Court of Appeals nullified proceedings for lack of jurisdiction, finding it to be accion publiciana requiring Regional Trial Court jurisdiction. The Supreme Court reversed, holding that Perea's possession was by tolerance and his refusal to vacate upon demand constituted unlawful detainer within Municipal Trial Court jurisdiction. The case establishes important precedent on distinguishing between ejectment actions and accion publiciana based on the nature of possession and pleading requirements.