Racaza v. Gozum
REITERATIONFacts
The Antecedents: Petitioners Germelina Torres Racaza and Bernaldita Torres Paras are the registered co-owners of a parcel of land with a 2-storey, 3-door apartment situated in Santolan, Pasig City. The property was formerly owned by their deceased father, Carlos Torres. Respondent Ernesto Gozum occupied a portion of this property since 1981, initially paying P3,500.00 monthly rental. After the death of Carlos Torres, Gozum continued his occupancy. Petitioners sent a letter of demand to vacate on July 1, 1995, after a failed barangay conciliation, and subsequently filed an ejectment case which was dismissed on a technicality. Almost two years later, on May 27, 1997, petitioners issued another demand letter, asserting the expiration of the verbal lease contract in July 1995 and Gozum's failure to pay rentals since then. When this demand was not heeded, petitioners initiated the present complaint for accion publiciana on June 4, 1997. Procedural History: Respondent filed a motion to dismiss, arguing lack of jurisdiction and non-compliance with P.D. No. 1508. The Regional Trial Court (RTC), Branch 158 of Pasig City, denied this motion, ruling that the case was an accion publiciana, not unlawful detainer, as it was filed more than one year after the initial demand to vacate. The RTC subsequently rendered a decision on September 30, 1998, in favor of the petitioners, ordering respondent to vacate the premises and pay rentals, attorney's fees, and costs. Respondent appealed to the Court of Appeals (CA), raising several errors, including the RTC's finding of a legal right to possession and the validity of the lease contract. While the appeal was pending, petitioners filed a motion to dismiss or for execution pending appeal, citing the expiration of the lease contract. The CA, however, reversed the RTC's decision and dismissed the case, holding that the RTC lacked jurisdiction because the complaint was filed within one year of the last demand letter, making it an unlawful detainer case cognizable by the first-level courts. Petitioners' motion for reconsideration was denied. The Petition: Petitioners seek review on certiorari under Rule 45 of the Rules of Court, arguing that the CA erred in declaring the RTC proceedings void. They contend that they correctly filed an accion publiciana, that respondent actively participated in the trial and did not raise jurisdictional issues on appeal, and that the CA ignored the mootness of the appeal due to the lease contract's expiration. Respondent, in his comment, maintains that the CA correctly set aside the RTC decision due to lack of jurisdiction, reiterating his earlier motion to dismiss and the CA's reasoning. Petitioners, in their reply, assert that respondent is estopped from raising jurisdictional issues due to his active participation. The Supreme Court ultimately granted the petition, reversing the CA's decision and reinstating the RTC's judgment, finding that the RTC had jurisdiction and that respondent was estopped from questioning it.
Issue(s)
Whether the Regional Trial Court (RTC) had jurisdiction over the 'accion publiciana' considering a second demand letter was sent within one year of the filing. Whether respondent Gozum is estopped from challenging the jurisdiction of the RTC after active participation in the proceedings. Whether the expiration of the alleged written lease contract during the pendency of the appeal rendered the case moot.
Ruling
The Supreme Court granted the petition, 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 RTC had jurisdiction over the case and that the respondent was estopped from questioning the jurisdiction.
Ratio Decidendi
On Issue 1: The Supreme Court held that the RTC properly exercised jurisdiction. Jurisdiction is determined by the allegations in the complaint, which showed the lease was on a month-to-month basis and had been terminated via a demand letter dated July 1, 1995. Under Article 1687 of the Civil Code, a month-to-month lease expires at the end of every month. The one-year period for filing an unlawful detainer suit is reckoned from the date of the first dispossession or the original demand to vacate. The Court clarified that subsequent demands which are merely reminders or reiterations of the original demand do not operate to renew the one-year period. Since the 'accion publiciana' was filed in June 1997, more than one year had passed since the July 1995 demand, ousting the MeTC of jurisdiction and making the RTC the proper forum. On Issue 2: The Court ruled that respondent Gozum was barred by estoppel from challenging the RTC's jurisdiction based on the second demand letter. Although Gozum filed an initial motion to dismiss, he did not challenge the RTC's jurisdiction specifically regarding the May 27, 1997 letter during the trial or in his initial appeal. He actively participated in all stages of the case, testified, and sought affirmative relief based on a purported 10-year lease. Applying the doctrine in Tijam v. Sibonghanoy (G.R. No. L-21450), a party's active participation in all stages of a case effectively estops them from later challenging the court's jurisdiction after receiving an unfavorable judgment. On Issue 3: The Court noted that the controversy had become moot and academic. Respondent Gozum's defense was anchored on a written lease contract that allegedly expired on September 30, 1999. By the time the Court of Appeals rendered its decision in 2000, even this claimed contract had already ended. The Court emphasized that this admission by the respondent was binding and effectively extinguished his right to possess the property, regardless of the jurisdictional dispute. The CA should have taken cognizance of this material fact which rendered the issue of who had the better right of possession moot.
Main Doctrine
A party who actively participates in the proceedings before a court, invoking its authority to grant affirmative relief, is estopped from later challenging that court's jurisdiction, even if the court's decision is later found to be rendered without jurisdiction. Furthermore, an action for recovery of possession filed more than one year after the cause of action accrued, based on the expiration of a month-to-month lease, falls under accion publiciana, not unlawful detainer.