Sunny Motors Sales, Inc. v. Honorable Court of Appeals
REITERATIONFacts
The Antecedents: Respondent Lolita L. Santiago leased a portion of a property in Quezon City for use as a warehouse. Shortly after the lease commenced, petitioner Sunny Motors Sales, Inc., claiming to be the new owner, forcibly entered the entire property, including the leased portion, and prevented respondent Santiago from accessing and using her leased premises. This action effectively dispossessed respondent Santiago without prior notice. Procedural History: Respondent Santiago filed a complaint for damages with a temporary restraining order and/or preliminary injunction against the lessor and Sunny Motors Sales, Inc. in the Regional Trial Court (RTC) of Quezon City. Petitioner Sunny Motors Sales, Inc. filed a motion to dismiss, arguing that the RTC lacked jurisdiction because the complaint was essentially one for forcible entry, which falls under the exclusive jurisdiction of the Metropolitan Trial Court. The RTC denied the motion to dismiss. Petitioner then filed a petition for certiorari and prohibition with the Court of Appeals (CA), assailing the RTC's denial of the motion to dismiss. The CA denied the petition, affirming the RTC's jurisdiction. The Petition: Petitioner Sunny Motors Sales, Inc. filed this petition for review on certiorari with the Supreme Court, seeking to set aside the decision of the Court of Appeals. Petitioner argues that the amended complaint filed by respondent Santiago is an action for forcible entry, not for damages and injunction, and therefore the Regional Trial Court lacks jurisdiction. The core of petitioner's argument is that the allegations in the complaint, particularly those describing the forcible entry and dispossession, establish a cause of action for forcible entry, which is cognizable by inferior courts, not the RTC.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over a complaint that labels itself as an action for damages but alleges facts constituting forcible entry.
Ruling
The petition is granted. The appealed decision of the Court of Appeals is reversed, and the amended complaint in Civil Case No. Q-95-22644 is ordered dismissed for lack of jurisdiction.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Regional Trial Court (RTC) did not have jurisdiction over the subject matter. Following the principle in Morta, Sr. v. Occidental, the Court held that jurisdiction is determined by the allegations in the complaint, regardless of whether the plaintiff is entitled to recover. Upon examination of the specific allegations, the Court found that while Santiago claimed she 'remained in possession' in one paragraph, other paragraphs explicitly detailed how Sunny Motors' security guards 'suddenly entered' and 'barred' her from the premises. These allegations describe the deprivation of physical possession through force and intimidation, which are the hallmarks of Forcible Entry under Rule 70, Section 1 of the Rules of Court. Applying Drilon v. Guarana, the Court noted that the relief actually sought was restoration of possession and damages for breach of the lease contract following a forceful intrusion. Consequently, pursuant to Section 33 of Batas Pambansa Blg. 129, the case falls under the original exclusive jurisdiction of the Metropolitan Trial Court (MeTC).
Main Doctrine
The nature of an action and the jurisdiction of a court are determined by the allegations in the complaint and the character of the relief sought, not by the defenses raised by the defendant. A complaint alleging disruption of possession through force, intimidation, threat, strategy, or stealth, even if seeking damages, may fall under forcible entry, which is within the exclusive jurisdiction of inferior courts.