Reyes v. Sta. Maria

Summary

The Supreme Court reversed a Court of First Instance dismissal order that ruled petitioners' property possession action lacked jurisdiction. Petitioners sought to recover a residential lot from respondents who refused to vacate, claiming they had purchased the property. The lower court dismissed the case as merely unlawful detainer within municipal court jurisdiction. The Supreme Court held this was an accion publiciana for recovery of the right to possess (possession de jure), not just physical possession (possession de facto), because respondents asserted contrary ownership claims. The Court distinguished three types of possession actions and emphasized that accion publiciana falls within Court of First Instance jurisdiction. The case was remanded for trial on the merits, establishing important precedent on jurisdictional determination for property possession cases involving competing ownership claims.