FACTS:

The case involves a forcible entry dispute between respondents spouses Gregorio de Leon and Zenaida Faustino, who claimed to be the original claimants and possessors of a parcel of agricultural land in Norzagaray, Bulacan, and petitioner Hernando Gener. The respondents alleged that they extended their occupation and cultivation to the land after the Angat River changed its course during a flood in 1978, leaving the land elevated and dried up. On the other hand, petitioner claimed to be the real owner and possessor of the land, supported by a notarized deed of sale. He also accused the respondents of forcibly entering his lot and filed criminal cases against individuals allegedly working for the respondents. The Municipal Trial Court of Norzagaray heard the case and received testimonies from witnesses for both parties, including Ignacio Cadungol who testified for the respondents.

The disputed property is a piece of land declared for taxation purposes in the name of the defendant, Hernando Gener, but has been physically possessed by Hernando Gener since 1989. Hernando Gener planted langka trees on the land, which had grown to a height of four feet. However, Hernando Gener destroyed the banana trees on the land that had been planted by Rolly Gener, on the pretext of passing by but instead caused them to be replaced with banana trees and other improvements. Hernando Gener reported this fact to the owner, Gregorio de Leon, and Zenaida Faustino, who scolded him.

The plaintiffs presented witnesses, including Teodoro Mendoza, who testified that Gregorio de Leon had taken possession of the land even before the pre-war period by introducing improvements like coconut and mango trees. He also testified that he saw Hernando Gener on the land only in 1990. Another witness, Andres Palad, corroborated Mendoza's testimony, stating that the De Leon father and son had long been in occupation of the land. Zenaida Faustino de Leon, the plaintiff, testified that she and her husband had been in possession of the land since they got married in 1950, and they introduced improvements like banana, coconut, kaimito, papaya, and langka trees. She also presented a Sketch Plan prepared by a geodetic engineer showing the improvements on the land. Balagtas P. San Pedro, a supervisor at the Provincial Assessor's Office, testified that the property adjacent to the land in question was owned by Gregorio de Leon and Zenaida Faustino. On cross-examination, San Pedro admitted that he did not know who the actual possessor of the land was and that his function was merely to determine the tax due and assessment. Marcelino Samson and Norma Maclang, employees of the Municipal Assessor's Office, provided additional information on the preparation of the tax declaration and sketch plan.

In his defense, Hernando Gener claimed that he did not forcibly enter the plaintiffs' lot as alleged but that it was actually the plaintiffs who forcibly entered his lot, which he had bought from Benjamin Joaquin. He presented a Deed of Sale to prove his ownership of the land. Hernando Gener also claimed that Gregorio de Leon and Zenaida Faustino did not possess the land since they resided five hundred meters away. He filed a criminal case against them for entering his property without permission. Hernando Gener declared the land under his name and paid taxes for it. He suffered damages and incurred attorney's fees due to the filing of this case.

After considering the conflicting evidence, the Municipal Trial Court of Norzagaray, Bulacan rendered a judgment in favor of the plaintiffs, ordering the defendant to vacate the portion described in Tax Declaration No. ARP-4675 and pay the plaintiffs P1,000.00 as litigation expenses.

ISSUES:

1. Whether or not respondents' complaint for forcible entry was filed beyond the one-year reglementary period.

2. Whether or not respondents are guilty of laches.

3. Whether or not the Court of Appeals disregarded or misapprehended material facts that would have altered the result of its judgment.

4. Whether or not the joint affidavit of Adriano de Guzman, Gorgonio de Leon, and Gregorio Sison recognizing Proceso Joaquin as a boundary owner is admissible as a declaration against interest.

5. Whether or not it was unclear whether the disputed property formed part of the purchase package.

6. Whether or not petitioner was the initial occupant of the contested lot.

7. Whether or not petitioner forcibly excluded respondents from the lot in question.

8. Whether or not the Regional Trial Court treated the case as an accion publiciana.

9. Whether the findings of fact of the appellate court have any basis

10. Whether the evidences presented by the petitioner showing his prior possession of the disputed property were given weight by the appellate court

11. Whether the Municipal Trial Court should have taken judicial notice of the pendency of a criminal case involving the disputed property

12. Whether the Municipal Trial Court should have taken judicial notice of the criminal cases involving the subject parcel of land.

13. Whether the cause of action for forcible entry has already prescribed.

RULING:

1. The Supreme Court did not provide a ruling-specific portion in this part of the text.

2. The Supreme Court finds sufficient basis to deviate from the rule that the findings of fact of the appellate court are generally conclusive. The extant evidence and prevailing law support a finding different from the conclusion of the appellate court.

3. In ejectment cases, the only issue for resolution is who is entitled to the physical or material possession of the property involved, regardless of any claim of ownership. The plaintiff who can prove prior possession de facto may recover such possession, even from the owner himself. In this case, the petitioner presented documentary evidence of prior possession, which should have been given weight by the appellate court.

4. The Municipal Trial Court should have taken judicial notice of the pendency of a criminal case involving the disputed property, as it is relevant to the issue of possession.

5. The Municipal Trial Court should have taken judicial notice of the criminal cases involving the subject parcel of land. While courts are generally not authorized to take judicial notice of the contents of the records of other cases, this rule is subject to the exception that "in the absence of objection and as a matter of convenience to all parties, a court may properly treat all or any part of the original record of the case filed in its archives as read into the records of a case pending before it, when with the knowledge of the opposing party, reference is made to it, by name and number or in some other manner by which it is sufficiently designated."

6. The cause of action for forcible entry has already prescribed. Forcible entry cases must be filed within one year from the date of actual entry on the land. After the lapse of the one year period, the remedies of the party dispossessed of a parcel of land is to file either an accion publiciana or an accion reinvindicatoria. Consequently, since the respondents' cause of action for forcible entry has prescribed, the Municipal Trial Court was without jurisdiction to hear and decide the subject ejectment case.

PRINCIPLES:

• The complaint for forcible entry must be filed within one year from the date of actual entry on the land, or from the date when the lawful possessor was deprived of its possession through force, intimidation, threat, strategy, or stealth (Issue 2).

• Laches is the negligence or omission to assert a right within a reasonable time, warranting an inference that the party entitled to assert it either has abandoned it or declined to assert it (Issue 3).

• Declarations against interest are admissible as evidence under Section 28, Rule 130 of the Rules of Court (Issue 4).

• The burden of proving the sale of a specific tract of land lies with the party asserting it. The evidence must clearly and directly prove the sale (Issue 5).

• The initial occupant of a contested lot refers to the person who first took actual possession of the land (Issue 6).

• To establish forcible entry, there must be clear proof that the entry is made by means of force, intimidation, threat, strategy, or stealth (Issue 8).

• An accion publiciana is an ordinary civil action for the recovery of the right of possession (Issue 8).

• In petitions for review on certiorari, the Supreme Court's jurisdiction is limited to reviewing questions of law. Findings of fact of the appellate court are generally conclusive, but if said findings do not conform to the evidence on record, the Supreme Court may review and reverse them.

• In ejectment cases, the issue is solely the right to possession of the property, independent of any claim of ownership. Priority in time is the pivotal point in resolving the issue of possession.

• The plaintiff in an action for forcible entry must allege and prove prior physical possession of the property until it was unlawfully deprived by the defendant. The one-year period to bring such action is generally counted from the date of actual entry by the defendant.

• Documentary evidence may carry more weight than mere testimonial evidence in proving prior possession.

• Oral testimony is not as reliable as written or documentary evidence.

• Courts may take judicial notice of the contents of the records of other cases when there is no objection and it is convenient to all parties.

• Forcible entry cases must be filed within one year from the date of actual entry on the land. After the one year period, the remedies available are accion publiciana and accion reinvindicatoria.