Labastida v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents, owners of a parcel of land, leased a portion to petitioners on a month-to-month basis for P200.00 monthly rental. In late 1979, private respondents verbally notified occupants, including petitioners, to vacate to allow the construction of a commercial building. Petitioners allegedly repaired their building, made additional constructions, partitioned the first story, and subleased portions without consent. On October 24, 1980, and again on February 20, 1983, private respondents sent written demands to vacate. Petitioners failed to vacate. Procedural History: On December 6, 1983, private respondents filed a case for recovery of possession and damages with preliminary mandatory injunction before the Regional Trial Court (RTC) of Iligan City. Petitioners filed a motion to dismiss, arguing lack of jurisdiction over the person and subject matter, and lis pendens due to a prior ejectment case. The RTC denied the motion, ruling that the complaint was filed after one year from the date of demand and that the prior ejectment case was dismissed before the filing of the RTC case. The RTC rendered judgment for private respondents. Petitioners appealed to the Court of Appeals (CA), which affirmed the RTC decision. The CA later held petitioners estopped from questioning jurisdiction. The Petition: Petitioners seek review of the CA decision, primarily questioning the RTC's jurisdiction.
Issue(s)
Whether the RTC had jurisdiction over the unlawful detainer case. Whether the action filed was for unlawful detainer (desahucio) or recovery of possession (accion publiciana), and whether the action was brought within one year from the last demand to vacate. Whether the petitioners were estopped from asserting the RTC lacked jurisdiction.
Ruling
The decision of the Court of Appeals is REVERSED. The proceedings before Branch 4, RTC of Iligan City in Civil Case No. 186 are declared NULL and VOID for lack of jurisdiction of that court.
Ratio Decidendi
On the nature of the action and jurisdiction: The Court clarified that although the complaint was entitled "For Recovery of Possession, Damages, with Preliminary Mandatory Injunction," the allegations clearly established an unlawful detainer case. The complaint alleged ownership, a month-to-month lease, repeated demands to vacate, and petitioners' refusal to leave, which are hallmarks of unlawful detainer. The Court reiterated that Rule 70, Section 1 of the Revised Rules of Court provides that an action for unlawful detainer must be instituted within one year after such unlawful deprivation or withholding of possession. The proper court for such an action is the inferior court (Municipal Trial Court in Cities in this case), not the Regional Trial Court. On the one-year period for filing and the nature of the action: The Court emphasized that in cases with multiple demands to vacate, the one-year period for filing an unlawful detainer case is reckoned from the date of the last demand. In this case, the last written demand was dated February 20, 1983, and the complaint was filed on December 6, 1983. This falls within the one-year period prescribed by Rule 70, Section 1. Therefore, the RTC, which is not the proper venue for unlawful detainer cases filed within one year, lacked jurisdiction. The Court found that the RTC would only have jurisdiction if the deprivation of possession was committed through means other than those enumerated in Rule 70, or if the period of dispossession under Rule 70 had lasted for more than a year. Neither was established. On estoppel and the CA's reasoning: The Court corrected the CA's misstatement regarding the filing date of the complaint, noting it was filed in 1983, not 1984, thus confirming it was filed within the one-year period. The Court rejected the CA's finding of estoppel, stating that the petitioners' initial denial of receiving the February 20, 1983 notice, followed by their later admission for the purpose of arguing for MTC jurisdiction, did not estop them from asserting that the RTC lacked jurisdiction because the case was filed within the one-year period.
Main Doctrine
The one-year period for filing an unlawful detainer case is reckoned from the date of the last demand to vacate, and a Regional Trial Court lacks jurisdiction over an unlawful detainer case filed beyond one year from the last demand.