Lavibo v. Court of Appeals
REITERATIONFacts
The Antecedents: Tradal Ventures and Management Corporation ("Tradal") entered into a contract to sell a unit to Ofelia Lavibo for P1,500,000.00. The contract stipulated that the buyer would not occupy the property until the full release of her loan from BPI-Family Bank. Despite this, Tradal allowed Lavibo to occupy the unit after she issued two postdated checks totaling P330,000.00. These checks were subsequently dishonored due to a closed account. Tradal demanded that Lavibo vacate the premises, but she failed to do so or redeem the checks. Procedural History: Tradal filed a complaint for ejectment against Lavibo and Atty. Benjamin Bargas before the Metropolitan Trial Court (MeTC). The defendants moved for dismissal, arguing that the complaint stated no cause of action for ejectment, was based on a contract to sell (not a lease), sought damages beyond the MeTC's jurisdiction, and was thus outside its cognizance. The MeTC dismissed the complaint, holding that the action was for rescission of the contract to sell, not ejectment, and that the MeTC lacked jurisdiction over rescission cases. The Regional Trial Court (RTC) affirmed the MeTC's decision. Tradal appealed to the Court of Appeals (CA), which reversed the RTC and ordered the respondents to vacate the premises and pay rental value. The Petition: Petitioners seek, via a petition for review on certiorari, the reversal of the Court of Appeals' decision and resolution denying reconsideration.
Issue(s)
Whether the MeTC has jurisdiction over the ejectment case filed by Tradal, considering the allegations in the complaint and the nature of the relief sought. Whether the action for ejectment was premature, given the existing contract to sell and the absence of prior rescission.
Ruling
The Supreme Court reversed and set aside the decision of the Court of Appeals and reinstated the decision of the Regional Trial Court. The Court held that the ejectment case was premature and that the MeTC correctly dismissed the complaint for want of cause of action.
Ratio Decidendi
On the jurisdiction of the MeTC: The Court reiterated that jurisdiction is determined by the allegations of the complaint. Tradal's complaint, though captioned as ejectment, alleged entitlement to rescission and sought damages beyond the MeTC's jurisdiction. The complaint detailed violations of the contract to sell (dishonored checks, refusal to vacate) as grounds for rescission. Since the MeTC lacks jurisdiction over rescission, it could not take cognizance of the case, especially with the contract's validity presumed at that stage. On the prematurity of the ejectment action: An action for ejectment is only available after the contract to sell has been rescinded, either by notarial act or court action. Since the contract to sell between Tradal and the defendant still subsisted and had not been properly rescinded, the action for ejectment filed by Tradal was premature. Therefore, the dismissal of the complaint by the MeTC was rightly sustained by the RTC, and the Court of Appeals erred in reversing it.
Main Doctrine
An action for ejectment is premature if it is based on the violation of a contract to sell that has not yet been rescinded, either by notarial act or by a court action for rescission. The jurisdiction of a court in an ejectment case is determined by the allegations in the complaint.