Lim Kieh Tong, Inc. v. Court of Appeals
REITERATIONFacts
The Antecedents: Reginaldo Y. Lim (private respondent) had occupied Room 301 of a building owned by Lim Kieh Tong, Inc. (petitioner). Although he later moved to a different residence, he continued to use Room 301 to store personal belongings. The building had a common main door, and occupants were provided with a key. On September 30, 1987, Lim discovered that the lock on the main door had been changed, rendering his key useless and preventing him from accessing Room 301. He incurred expenses for new law books as he could not retrieve his own. Procedural History: Lim initially filed a complaint before the Metropolitan Trial Court (MTC) of Manila, denominated as an action for damages with injunction. This case was dismissed for lack of jurisdiction. He then filed a second complaint on October 23, 1987, reiterating the same allegations. The MTC issued a temporary restraining order compelling petitioner to provide Lim with the appropriate keys. Petitioner then filed a special civil action for certiorari with the Court of Appeals, seeking to annul the MTC's restraining order and to prevent the MTC from further taking cognizance of the case. The Court of Appeals dismissed the petition, and a subsequent motion for reconsideration was denied. Petitioner's motion to dismiss the MTC case was also denied, as it was considered a prohibited pleading under the Rules on Summary Procedure. The Petition: Petitioner seeks review of the Court of Appeals' decision, arguing that the underlying action filed by Lim is one for specific performance, not forcible entry and detainer, and therefore jurisdiction lies with the Regional Trial Court. Petitioner contends that the MTC lacked jurisdiction due to the nature of the claim and the alleged failure to specifically allege damages. The core of the petition is the assertion that the MTC should not have taken cognizance of the case, as it falls outside the purview of summary procedure and forcible entry actions.
Issue(s)
Whether the action filed by the private respondent is one for forcible entry and detainer or for specific performance, and whether the Metropolitan Trial Court has jurisdiction over the case.
Ruling
The petition is denied. The Supreme Court affirmed the ruling of the Court of Appeals, holding that the action filed by the private respondent is one for forcible entry and detainer, and thus falls within the jurisdiction of the Metropolitan Trial Court.
Ratio Decidendi
On the nature of the action and jurisdiction: The Court held that the suit is one for forcible entry and detainer under Rule 70 of the Rules of Court. The facts alleged in the complaint clearly show that private respondent retained possession of Room 301, which he claimed the right to use and enjoy. Petitioner prevented him from enjoying this right by changing the lock to the common main door, thereby depriving him of ingress and egress. This act of changing the lock without the private respondent's knowledge or consent constitutes dispossession through stealth, fitting the definition of forcible entry. The Court emphasized that the purpose of forcible entry is to protect the party in peaceable possession from being turned out by strong hand, violence, or terror, and that a party out of possession must resort to the law alone. The issue involved is physical possession (de facto), not juridical possession (de jure) or ownership. Therefore, the Metropolitan Trial Court correctly denied the motion to dismiss and correctly found applicability of the Rule on Summary Procedure, as a motion to dismiss is a prohibited pleading under Section 15 of the 1983 Rules on Summary Procedure. The Court reiterated that what confers jurisdiction on inferior courts in forcible entry and illegal detainer cases is the nature of the action, not the amount of unpaid rentals or damages involved, as these are merely incidental to the main action. The ruling in Singson vs. Aragon was cited regarding the award of exemplary and moral damages, stating that even if not specifically alleged, the MTC could still grant them if the total claim does not exceed the jurisdictional amount. The Court also cited numerous cases supporting the availability of the relief for forcible entry and detainer to lessees or tenants against unlawful deprivation of possession within one year.
Main Doctrine
An action where a party is deprived of possession of a room by the changing of the lock to the common main door, preventing ingress and egress, constitutes forcible entry and detainer, not specific performance, and falls under the jurisdiction of the Metropolitan Trial Court under summary procedure.