Laraño v. Calendacion
REITERATIONFacts
The Antecedents: Petitioner Baby Arlene Laraño owned a riceland. On September 14, 1998, she executed a Contract to Sell with respondents Spouses Alfredo and Rafaela Calendacion for a portion of the land for ₱5 Million, payable in installments until September 2001. Pending full payment, possession was transferred to respondents, who were obligated to account for and deliver the harvest to petitioner. Respondents failed to pay installments and to account for the harvest. Procedural History: On March 7, 2000, petitioner sent a demand letter to vacate. When ignored, she filed a complaint for unlawful detainer before the Municipal Trial Court (MTC) on April 5, 2000. The MTC ruled in favor of petitioner, ordering respondents to vacate, pay compensation, attorney's fees, and litigation expenses. Respondents appealed to the Regional Trial Court (RTC), which affirmed the MTC decision with modification on the compensation amount. Respondents then filed a Petition for Review with the Court of Appeals (CA). The Petition: The CA set aside the RTC decision and dismissed the complaint for unlawful detainer, ruling that the MTC lacked jurisdiction because the issues involved interpretation, enforcement, and rescission of the contract, which are beyond the MTC's competence. The CA found that the case was not a mere detainer suit but one incapable of pecuniary estimation, thus falling under the RTC's exclusive original jurisdiction. Petitioner filed the present petition for review on certiorari.
Issue(s)
Whether the Court of Appeals committed grave error in giving due course to the petition for review despite the lack of verification. Whether the Court of Appeals erred in dismissing the case for lack of jurisdiction of the Municipal Trial Court over the unlawful detainer complaint, considering the allegations in the complaint and the nature of the case. Whether the Court of Appeals erred in not affirming the decisions of the MTC and RTC ordering the eviction of respondents, given the jurisdictional issues.
Ruling
The petition is denied. The Decision of the Court of Appeals dated May 13, 2003, setting aside the RTC decision and dismissing the complaint for unlawful detainer for want of jurisdiction, is affirmed.
Ratio Decidendi
On the issue of verification: The Court held that the lack of verification in a pleading is a formal defect that can be excused or dispensed with in meritorious cases, as it is neither jurisdictional nor always fatal. Furthermore, the petitioner failed to raise this issue before the Court of Appeals, thus waiving any objection to the formal flaws of the petition. Points of law not raised before the lower court cannot be raised for the first time on appeal. On the jurisdiction of the MTC: The Court reiterated that jurisdiction in ejectment cases is determined by the allegations in the complaint, not by the defenses set up by the defendant. For an unlawful detainer action to prosper, the complaint must allege two requisites: (a) failure to pay installments or comply with contract conditions, and (b) a demand to pay or comply and to vacate within the periods specified in Rule 70. The complaint must allege that such demands were made; otherwise, the MTC cannot acquire jurisdiction. In this case, the complaint failed to state that petitioner made demands upon respondents to comply with the contract terms (payment of installments and accounting of harvests) and that the 10-day period to vacate was insufficient under the law. The Court also found that the basic issue raised in the complaint was not merely possession but the interpretation, enforcement, and/or rescission of the Contract to Sell. Rescission of a contract is a power vested in the Regional Trial Court (RTC), and it is the basis for the illegality of possession. Without judicial intervention and determination, a stipulation allowing one party to take possession upon violation of the contract cannot confer the right to do so if objected to. Therefore, the matter was beyond the jurisdiction of the MTC. On the decisions of the MTC and RTC: Given that the MTC lacked jurisdiction over the unlawful detainer complaint because the action involved the interpretation, enforcement, and/or rescission of the Contract to Sell, and the complaint failed to properly allege demands, the Court of Appeals did not err in not affirming the decisions of the MTC and RTC ordering the eviction of respondents.
Main Doctrine
For an unlawful detainer case to prosper, the complaint must allege that a demand to pay or comply with the contract and a demand to vacate were made upon the defendant, and that the defendant failed to comply with these demands within the periods prescribed by law. Failure to allege these jurisdictional requirements renders the MTC without jurisdiction over the case.