La Campana Food Products, Inc. v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner La Campana Food Products, Inc. (lessor) leased a building and lot to private respondent Cascade Commercial Corporation (lessee) for four years starting March 1, 1982. On January 22, 1986, La Campana sent a demand letter for unpaid rentals and water bills totaling P73,902.00, giving Cascade three days to pay, otherwise, legal action would be taken. Procedural History: On February 19, 1986, La Campana filed an ejectment case with preliminary attachment against Cascade in the Metropolitan Trial Court (MTC) of Quezon City, alleging non-payment of rentals since August 1985 and demanding P73,820.60 in unpaid rentals, plus P15,000 monthly for the use of the premises starting March 1986. Cascade filed a Motion to Dismiss and Motion for Discharge of Attachment, arguing the case was for a sum of money exceeding the MTC's jurisdiction and that summons was served after it vacated the premises on March 3, 1986. The MTC denied these motions. Cascade then filed a petition for certiorari and prohibition with the Court of Appeals (CA), again assailing the MTC's jurisdiction. Meanwhile, Cascade filed its Answer with Counterclaim in the MTC. The CA denied Cascade's petition, holding it should have been filed with the Regional Trial Court (RTC). The MTC, on April 6, 1987, ruled that Cascade vacated on March 3, 1986, and ordered Cascade to pay P40,237.70 in unpaid rentals, P50,000 as attorney's fees, and costs, dismissing the counterclaims. Cascade appealed to the RTC, reiterating jurisdictional arguments. The RTC affirmed the MTC decision. Cascade again petitioned the CA, this time arguing La Campana failed to allege a demand to vacate, which is an indispensable averment for unlawful detainer. The CA reversed the RTC decision, dismissing the complaint, holding that the demand to vacate is jurisdictional and its absence renders the MTC without jurisdiction. Both La Campana and the MTC judge filed motions for reconsideration, which the CA denied. The Petition: The Supreme Court reviewed the CA's decision, considering whether the MTC had jurisdiction over the ejectment case, particularly in light of the alleged lack of a demand to vacate.
Issue(s)
Whether the Metropolitan Trial Court had jurisdiction over the ejectment case, considering both the alleged absence of a specific demand to vacate the premises and the respondent's initial participation in the proceedings. Whether the private respondent was barred by estoppel or laches from assailing the jurisdiction of the Metropolitan Trial Court, given their actions in the lower court.
Ruling
The Supreme Court reversed and set aside the decision of the Court of Appeals and reinstated the decision of the Regional Trial Court affirming the Metropolitan Trial Court's ruling. The Court held that the private respondent was barred by estoppel and laches from assailing the jurisdiction of the Metropolitan Trial Court.
Ratio Decidendi
On the issue of jurisdiction and the absence of a specific demand to vacate, as well as the respondent's initial participation: The Court acknowledged that a demand to vacate is generally indispensable for unlawful detainer cases. While the demand letter from La Campana did not explicitly demand vacating, Cascade Commercial Corporation did not raise the lack of demand in the MTC or RTC. Cascade's Answer with Counterclaim in the MTC recognized the court's jurisdiction by seeking affirmative relief. Citing Jakihaca v. Aquino and Tijam v. Sibonghanoy, the Court emphasized that a party cannot invoke jurisdiction for affirmative relief and then deny it to escape liability. Cascade's actions constituted a voluntary submission to the MTC's jurisdiction. On the issue of estoppel and laches: The Court applied the principle that a party voluntarily submitting to a court's jurisdiction and participating in proceedings, seeking affirmative relief, is barred by estoppel or laches from later attacking that jurisdiction. This prevents parties from accepting favorable judgments while attacking unfavorable ones for lack of jurisdiction. Citing Tijam v. Sibonghanoy, the Court held that the defense of lack of jurisdiction is barred when a party has invoked the court's jurisdiction to secure affirmative relief. Cascade's filing of an answer and counterclaim barred them from belatedly questioning the MTC's jurisdiction on appeal.
Main Doctrine
A party who voluntarily submits to the jurisdiction of a court and seeks affirmative relief therefrom is barred by estoppel or laches from later assailing the court's jurisdiction, even on appeal.