Real Party in Interest - Forcible Entry

Notably, even public lands can be the subject of forcible entry cases as it has already been held that ejectment proceedings may involve all kinds of land. Thus, in the case at bench, while the parties are fighting over the possession of a government land, the courts below are not deprived of jurisdiction to render judgment thereon. Courts must resolve the issue of possession even if the parties to the ejectment suit are mere informal settlers.

Sans the presence of the awardee of the Certificate of Stewardship, the provision clearly allows Valeriana to institute the action for the recovery of the physical possession of the property against the alleged usurper.  She has a right or interest to protect as she was the one dispossessed and thus, she can file the action for forcible entry. Any judgment rendered by the courts below in the forcible entry action will bind and definitely affect her claim to possess the subject property.  The fact that Valeriana is not the holder of the Certificate of Stewardship is not in issue in a forcible entry case.  This matter already delves into the character of her possession. We emphasize that in ejectment suits, it does not even matter if the party’s title to the property is questionable (Valeriana Villondo Vs. Carmen Quijano, et al., G.R. No. 173606. December 3, 2012).