CAISIP v PEOPLE FACTS: Cabalag and her husband cultivated a parcel of land in Hacienda Palico, which was owned

d by Roxas y Cia. Caisip is the overseer of the land. The land cultivated was previously tenanted by the father of Cabalag. On a relevant date, Guevarra sought recognition as a lawful tenant from the Comprehensive Agrarian Reform Program but such was dismissed as it was held that he wasnt a tenant thereof. Thereafter, Roxas filed a case for forcible entry against Guevarra, on which he won and the court ordered Guevarra to vacate the lot.

Meanwhile, there was an altercation between Cabalag and Caisip over the cutting of sugar cane. She was being asked to leave by Caisip but she refused. Thereafter, she was charged with grave coercion. When she was again seen in the Hacienda and weeding, she was forcibly dragged by policemen and Caisip. This prompted for the filing a case for grave coercion.

ISSUE/HELD:

RATIO:

Whether Article 429 is applicable to the case at bar. NO.

Article 429 is inapplicable to the case at bar. The complainant didnt usurp or invade said lot. She had merely remained in possession thereof, even though the hacienda owner may have become its co-possessor. Appellants did not repel or prevent an actual or threatened unlawful physical invasion or usurpation of the property. They expelled the complainant from a property on which she and her husband were in possession even before the action for forcible entry was filed against them.

Neil Noe C. Reyes Property Ownership Principle of self-help & State of Necessity