It is settled that prior physical possession is indispensable only in actions for forcible entry but not in unlawful detainer. Since we have ruled that the MTC case filed against petitioner is one for unlawful detainer, petitioner's prior possession of the land is of no moment. Private respondents are entitled to its possessions from the time title was issued in their favor as registered owners. [G.R. No. 124292. December 10, 1996]
