Sales v. Barro
REITERATIONFacts
The Antecedents: This case originated from an ejectment complaint filed by the petitioners against the respondent and his wife. The petitioners alleged they were the owners of the lot in question, that the respondent constructed a shanty thereon without their consent, that the respondent had not paid rent, and that he refused their formal demand to vacate. The respondent denied these allegations, claiming his construction was tolerated as he acted as the property's caretaker and denied receiving any demand letter or summons from the barangay. Procedural History: The Metropolitan Trial Court (MeTC) of Manila ruled in favor of the petitioners, ordering the respondent to vacate the premises, pay rent, and reimburse attorney's fees. The Regional Trial Court (RTC) affirmed the MeTC's decision in its entirety. However, the Court of Appeals reversed the RTC's decision, finding that the ejectment complaint was substantially lacking in the requisite allegations for either forcible entry or unlawful detainer, and thus dismissed the complaint for lack of jurisdiction. The Petition: The petitioners seek review on certiorari of the Court of Appeals' decision. They argue that the appellate court erred in dismissing their ejectment complaint for failure to state a jurisdictional fact of prior physical possession and in not ruling that the respondent was estopped from questioning the Metropolitan Trial Court's jurisdiction. The petitioners contend their complaint was for unlawful detainer, not forcible entry, and that the respondent actively participated in the proceedings, thereby waiving any jurisdictional objections.
Issue(s)
Whether the Court of Appeals erred in dismissing the ejectment complaint on the ground that it failed to state the jurisdictional fact of prior physical possession. Whether the respondent was estopped from questioning the jurisdiction of the Metropolitan Trial Court.
Ruling
The petition is denied for lack of merit. The Court of Appeals did not err in dismissing the ejectment complaint.
Ratio Decidendi
On the first issue: The Court held that the Court of Appeals did not err in finding that the complaint was for forcible entry and correctly dismissed it. The petitioners' averment that the respondent constructed a shanty without their consent and their prayer for rent from January 2004, coupled with their acquisition of ownership only on January 6, 2004, indicated that they considered the occupation unlawful from the beginning, thus negating the element of tolerance required for unlawful detainer. Furthermore, the nature of an action is determined by the allegations in the complaint and the relief sought, not by the defenses in the answer. The complaint was fatally defective for forcible entry as it lacked the mandatory allegation of prior physical possession by the petitioners and deprivation thereof by force, intimidation, threat, strategy, or stealth. The Court reiterated that 'possession' in ejectment cases refers to physical possession, not legal possession. On the second issue: The Court affirmed that a court's jurisdiction may be raised at any stage of the proceedings, even on appeal, because jurisdiction is conferred by law and lack of it affects the court's authority. Estoppel cannot confer jurisdiction on a tribunal that lacks it. Therefore, the respondent was not estopped from questioning the MeTC's jurisdiction, and the appellate court could dismiss the case for lack of jurisdiction even motu proprio.
Main Doctrine
The nature of an ejectment action, whether forcible entry or unlawful detainer, is determined by the allegations in the complaint and the character of the relief sought, not by the defenses raised in the answer. A complaint for forcible entry is fatally defective if it fails to allege prior physical possession by the plaintiff and deprivation thereof by force, intimidation, threat, strategy, or stealth. Estoppel cannot confer jurisdiction on a court that lacks it.