Sison v. Cariaga
REITERATIONFacts
The Antecedents: Petitioner Laurence Sison and his co-donees became co-owners of Lot 23-B-11, designated as a ROAD LOT, by virtue of a Deed of Donation executed on December 14, 1999. After a relocation survey, it was discovered that respondent Eusebia Cariaga's house was erected on this lot. Petitioner repeatedly demanded that respondent vacate the property, with the last demand being a September 15, 2003 letter stating her occupation was illegal and merely tolerated. These demands were unheeded. Procedural History: Petitioner filed a complaint for unlawful detainer against respondent. The Municipal Circuit Trial Court (MCTC) ruled in favor of petitioner, finding that he established ownership by preponderance of evidence and ordered respondent to vacate. Respondent appealed to the Regional Trial Court (RTC), which reversed the MCTC decision and dismissed the complaint, holding that petitioner failed to substantiate his allegation of tolerated possession and thus the complaint did not satisfy the jurisdictional requirement for unlawful detainer. The Court of Appeals affirmed the RTC decision, holding that tolerance was not present from the inception of respondent's possession and that the case involved a boundary dispute, making unlawful detainer an improper remedy. Petitioner's motion for reconsideration was denied. The Petition: Petitioner seeks review of the Court of Appeals' decision, assailing its findings regarding the date respondent's house was erected, the nature of the dispute (claiming it is about possession, not ownership or boundary dispute), and the propriety of the unlawful detainer remedy. Petitioner argues he complied with the requirements for unlawful detainer as established in Benitez v. Court of Appeals.
Issue(s)
Whether petitioner availed of the proper remedy of filing a complaint for unlawful detainer, and whether the MCTC had jurisdiction over the case despite respondent's claim of ownership. Whether petitioner, by preponderance of evidence, should prevail in his unlawful detainer case, considering respondent's implicit admission of petitioner's ownership and the evidence presented.
Ruling
The Supreme Court ruled in favor of the petitioner. The Court of Appeals' decision was reversed and set aside, and the MCTC decision was reinstated. The Court held that the nature of an action and jurisdiction are determined by the allegations in the complaint, not the defenses raised. The complaint sufficiently established the elements of unlawful detainer, and the issue of ownership could be resolved to determine possession. Furthermore, by filing a petition to annul the sale and compel the Land Bank to sell Lot 23-B to them, respondent implicitly admitted petitioner's ownership of the subject lot, which forms part of Lot 23-B, and that her house stands on it.
Ratio Decidendi
On the propriety of the unlawful detainer remedy and jurisdiction: The Court held that the nature of an action and jurisdiction are determined by the allegations in the complaint and the relief sought, not by the defenses raised by the defendant. Petitioner's complaint clearly alleged that respondent's house was illegally constructed on the property after a relocation survey, that demands to vacate were made and unheeded, and that her occupation was illegal and tolerated. These allegations established the basic elements of unlawful detainer, vesting jurisdiction in the MCTC. The Court reiterated that in an ejectment case, the issue of ownership may be resolved solely to determine the issue of possession. The Court found that the respondent's claim of ownership did not divest the MCTC of its jurisdiction over the unlawful detainer case. On the merits of the unlawful detainer case: The Court found that respondent's filing of a petition before the DARAB to annul the sale of Lot 23-B to petitioner's predecessors-in-interest and to compel the Land Bank to sell the lot to them constituted an implicit admission of petitioner's ownership of the subject lot, which is part of Lot 23-B, and that her house was indeed erected thereon. This admission, coupled with the petitioner's evidence establishing his co-ownership and right to possession, supported the MCTC's finding in favor of the petitioner. The Court concluded that respondent's possession was without title, while petitioner had title but lacked possession, thus entitling petitioner to recover possession.
Main Doctrine
The nature of an action and which court has jurisdiction over it are determined by the allegations of the complaint and the character of the relief sought, not by the defenses set up in the Answer. An unlawful detainer complaint is proper when the allegations establish the basic elements of unlawful detainer, even if the defendant claims ownership, as the issue of ownership may be resolved only to determine the issue of possession in an ejectment case.