Sarona v. Villegas

Summary

This Supreme Court En Banc case established the crucial distinction between forcible entry and unlawful detainer for jurisdictional purposes. The Court held that the nature of defendants' initial entry into the property determines the cause of action, not when demand to vacate was made. Since defendants entered the land illegally without consent in 1958 and the lawsuit was filed beyond the one-year reglementary period in 1963, the municipal court lacked jurisdiction over what was essentially a forcible entry case. The decision clarified that tolerance must exist from the start of possession to constitute unlawful detainer, and that forcible entry cases cannot be transformed into unlawful detainer merely through delayed demand. The ruling emphasized the summary nature of ejectment proceedings and the importance of the one-year limitation period, directing that cases filed beyond this period must proceed as accion publiciana in the Court of First Instance.