Lee v. Po Lam
REITERATIONFacts
1. The Antecedents: Spouses Roy Po Lam and Josefa Po Lam (private respondents) filed an ejectment suit against Jose Lee (petitioner) for refusing to vacate a commercial lot and building they leased to him after the lease agreement expired. Jose Lee contested the ownership of the property, citing a Court of Appeals decision that declared Felix Lim (also a petitioner) as the owner of a portion and entitled to redeem the remainder. Felix Lim intervened in the ejectment case, questioning the Po Lams' right to collect rentals and subsequently filed separate cases challenging their ownership and possession. 2. Procedural History: The ejectment case, initially filed with the City Court of Legazpi, was transferred to a different branch after the presiding judge inhibited himself. Jose Lee's motion to suspend proceedings pending resolution of his other ownership cases was denied. Felix Lim's motion to dismiss the ejectment case for lack of jurisdiction was also denied. The Municipal Trial Court of Legazpi City ruled in favor of the Po Lams, declaring them lawful owners and ordering Jose Lee to vacate and pay accrued rentals. Jose Lee appealed this decision to the Intermediate Appellate Court (IAC). The IAC dismissed the appeal, ruling it should have been filed with the Regional Trial Court. Jose Lee's motion for reconsideration was denied, leading to the present petition. 3. The Petition: This is a petition for certiorari and mandamus seeking to annul the Municipal Trial Court's decision and the IAC's resolutions. Petitioners argue that the Municipal Trial Court acted without jurisdiction by deciding ownership in an ejectment case, and that the IAC erred in dismissing the appeal instead of certifying it to the proper court. The Supreme Court is asked to set aside the IAC's resolutions and remand the case to the Regional Trial Court for proper determination.
Issue(s)
Whether the Municipal Trial Court of Legazpi City, Branch I, acted without or in excess of jurisdiction, or with grave abuse of discretion when it decided the issue of ownership in the ejectment case. Whether the Intermediate Appellate Court acted without or in excess of jurisdiction, or with grave abuse of discretion when it dismissed the appeal instead of certifying it to the proper court.
Ruling
The Supreme Court set aside the resolutions of the Intermediate Appellate Court and remanded the case to the Regional Trial Court of Albay. The Court ruled that while the IAC erred in dismissing the appeal, the MTC had jurisdiction over the ejectment case, and the parties were estopped from questioning it. However, the appeal should have been directed to the Regional Trial Court, not the IAC, following Batas Pambansa Blg. 129.
Ratio Decidendi
On the jurisdiction of the Municipal Trial Court: The petition's contention that the respondent trial court lacked jurisdiction over the ejectment case due to the raised issue of ownership is without merit. At the time the ejectment complaint was filed on September 2, 1981, Section 3 of Republic Act No. 5967 was the governing law, granting City Courts concurrent jurisdiction with the Court of First Instance in ejectment cases where the question of ownership is brought in issue. This section explicitly states that the issue of ownership shall be resolved in conjunction with the issue of possession. Therefore, the respondent trial court had the legal authority to hear and decide the ejectment case, including the incidental issue of ownership, as it was the court that first acquired jurisdiction over the subject matter. The subsequent filing of cases by intervenor Felix Lim before the Court of First Instance did not divest the City Court of its jurisdiction, as the principle of first-come, first-served applies to courts with concurrent jurisdiction. Furthermore, the petitioners are estopped from questioning the jurisdiction of the trial court, having actively participated in the proceedings, filed pleadings, presented evidence, and sought affirmative reliefs, thereby submitting themselves voluntarily to the court's authority. This is in line with the doctrine established in Tijam vs. Sibonghanoy. On the action of the Intermediate Appellate Court: The petition's contention that the respondent Intermediate Appellate Court acted with grave abuse of discretion in dismissing the appeal instead of certifying it to the proper court is impressed with merit. While Section 5 of R.A. 5967 allowed direct appeals of City Court decisions to the Court of Appeals, this provision was effectively repealed by Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980), which took effect on August 14, 1981. Under Section 22 of BP 129, appellate jurisdiction over cases decided by Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts is vested in the Regional Trial Courts. Consequently, the appeal from the Municipal Trial Court's decision in Civil Case No. 2687 should have been filed with the Regional Trial Court, not the Intermediate Appellate Court. The Intermediate Appellate Court erred in dismissing the appeal outright, as Section 3 of Rule 50 of the Revised Rules of Court mandates that when an appealed case is erroneously brought to the Court of Appeals, it should certify the case to the proper court, which in this instance is the Regional Trial Court. Therefore, the resolutions of the IAC were erroneous for failing to follow the correct appellate procedure prescribed by BP 129.
Main Doctrine
A court with concurrent jurisdiction over ejectment cases where the issue of ownership is raised, which acquires jurisdiction first, excludes other courts from interfering. Parties who actively participate in the proceedings and seek affirmative relief cannot later question the jurisdiction of the court to which they submitted their cause.