Serdoncillo v. Spouses Benolirao
REITERATIONFacts
The Antecedents: The subject premises, Lot 666-H, was part of a larger estate subdivided by United Complex Realty and Trading Corporation (UCRTC). Private respondents-spouses Benolirao purchased the residential portion of Lot 666-H, and private respondent Carisima purchased Lot 666-I. A portion of Lot 666-H was also designated as a right of way for these lots. Petitioner Marciana Serdoncillo occupied portions of these lots but declined to purchase them, continuing to pay rentals. After rentals stopped, petitioner filed a consignation case, which she won. UCRTC later sold Lot 666-H to the Benolirao spouses. UCRTC filed a case for recovery of possession against petitioner, which was dismissed. Petitioner filed a case for annulment of sale, which was also dismissed. Private respondents then filed the present complaint for recovery of possession, alleging petitioner constructed a residence and pig pen on their right of way and front portions, obstructing ingress and egress, despite demands to vacate. Procedural History: The Regional Trial Court (RTC) ruled in favor of the private respondents, ordering petitioner to demolish illegal structures, vacate the property, and return possession. The Court of Appeals (CA) affirmed the RTC's decision. The Petition: Petitioner assails the CA's decision, arguing that the RTC and CA committed grave abuse of jurisdiction by deciding the case as an accion publiciana (recovery of possession) when it should have been an ejectment or unlawful detainer case, which falls under the jurisdiction of inferior courts. Petitioner also argues that the issue of her tenancy was settled in a previous case, making the current action barred by res judicata.
Issue(s)
Whether the RTC and CA committed grave abuse of jurisdiction in deciding the case as an accion publiciana instead of an unlawful detainer case. Whether the issue of petitioner's tenancy and her right to remain in possession is barred by res judicata based on a prior consignation case.
Ruling
The petition is dismissed. The decision of the Court of Appeals affirming the RTC's ruling is affirmed. The RTC and CA did not commit grave abuse of jurisdiction in taking cognizance of the case as an accion publiciana or accion reivindicatoria, and the prior consignation case does not bar the present action due to a lack of identity of causes of action.
Ratio Decidendi
On the issue of jurisdiction and the nature of the action: The Supreme Court reiterated the elementary rule that jurisdiction is determined by the allegations in the complaint, not by the defenses raised. The Court emphasized that if a complaint fails to aver facts constitutive of forcible entry or unlawful detainer, the proper remedy is an accion publiciana or accion reivindicatoria. In this case, the complaint alleged ownership by the private respondents and prayed for recovery of possession of their property and right of way, which were allegedly encroached upon by petitioner's structures. The complaint did not specify the means of entry or dispossession, nor did it characterize petitioner's possession as initially lawful but subsequently terminated. The Ocular Inspection Report further indicated encroachment and obstruction, supporting the characterization of the action as one involving a dispute over ownership and possession, thus falling within the RTC's jurisdiction. The Court distinguished this case from Bernabe and Medina, where the complaints sufficiently alleged facts for unlawful detainer or forcible entry, or where the nature of the dispute was clearly a lease termination. The Court cited Tenorio vs. Gomba for the principle that RTCs have jurisdiction over all actions involving possession of land except forcible entry and unlawful detainer, and that this action was neither. On the issue of res judicata: The Court found no identity of causes of action between the prior consignation case (Civil Case No. 5456) and the present recovery of possession case (Civil Case No. 7785). While there was an identity of parties (or successors-in-interest), the issue in the consignation case was the propriety of consigning rentals, whereas the present case requires the private respondents to prove their title and right to possess the premises against the petitioner's claim. The evidence required for each case is different; the consignation case did not delve into the ownership and right to possess the specific portions of land and right of way that are the subject of the current dispute. Therefore, the decision in the consignation case, which merely established petitioner's status as a tenant for the purpose of consignation, did not bar the private respondents from filing an action to recover possession based on their established ownership.
Main Doctrine
The jurisdiction of a court over the subject matter is determined by the allegations of the complaint, irrespective of whether the plaintiff is entitled to recover. The nature of the action pleaded, as appearing from the allegations in the complaint, and the character of the relief sought, determine jurisdiction. If the complaint fails to aver facts constitutive of forcible entry or unlawful detainer, the remedy should be an accion publiciana or an accion reivindicatoria.