Corporation v.

Treyes

FACTS:

 Corporation et al claimed to have occupied the subject public land lot for 25 years even before
being granted Fishpond Leases.
o However, Treyes allegedly forcibly and unlawfully entered the properties and barricaded
the entrance and harvested tons of fish in the ponds owned by Corporation el al.
o Treyes even allegedly ransacked and destroyed the church built by Corporation in the
properties
 Corporation et al then filed separate complaints for Forcible Entrey with temporary restraining
order and preliminary injunction and damages PLUS complaint for damages (the focus in this
case)
 Treyes filed a motion to dismiss the complaint for damages on three grounds:
o Litis pendendtia
o Res judicata
o Forum shopping
 RTC dismissed the complaint for damages on the ground of prematurity saying that “ damages
may only be maintained after a final determination on the forcible entry cases has been made”

ISSUE:

Whether or not a complainant in a forcible entry case can file an independent action for damages arising
after the act of dispossession had occurred even during the pendency of their separate complaints for
forcible entry.

RULING: YES. Corporation may institute a separate and independent complaint for damages even
during pendency of separate complaints for forcible entry, arising after the act of dispossession had
occurred based on the separate acts done after the dispossession such as the stealing of fish and
ransacking of the church.

 As per Dumo v. Espinas, it was settled that the only form of damages that may be recovered in
an action for forcible entry is the fair rental value or the reasonable compensation for the use
and occupation of the property
o this is because the only issue to be resolved in a case for forcible entry is rightful
possession and the only damages one could recover from such action for forcible entry
is that which the plaintiff could have had if he was still the possessor of the property
o the only damages you can get is what you lost when you loss material possession
 Everything else should be claimed by ordinary action

 This is different from the case of Dev’t Corporation v. CA in which their claim for damages
separate from forcible entry with damages was dismissed on the ground of litis pendentia
(identity between two pending actions with respect to rights asserted, reliefs prayed for, is such
that when judgment is done on one, res judicata will result in the remaining action or simply
put, two cases are so similar that judgment of one will render affect the other decision
considerably)
o In Dev’t Corporation case, the separate action for damages is based on the alleged
forcible takeover of the leased premises by the petitioner in that case while the action
for forcible entry with damages was asking for damages for the loss sustained by the
plaintiff
o Basically, these are the damages asked for are from THE SAME injury in the forcible
entry case (they are both fair rental value or the reasonable compensation for the use
and occupation of the property)

 In the present case though, the damages asked for in the forcible entry case is based on the
dispossession while the action for damages is based on acts done AFTER dispossession such as
the carting away of fish and the ransacking of the church.