Nuñez v. SLTEAS Phoenix Solutions, Inc.
REITERATIONFacts
The Antecedents: Respondent SLTEAS Phoenix Solutions, Inc. (SLTEAS) acquired a 635.50 square meter parcel of land in Intramuros, Manila, through a Deed of Assignment in 1999. The property was left idle. In October 2003, an ocular inspection revealed that petitioner Hubert Nuñez and 21 others occupied the property. SLTEAS filed a complaint for forcible entry against Vivencia Fidel, later amended to implead Nuñez and the other occupants. Procedural History: The Metropolitan Trial Court (MeTC) Manila, Branch 4, found that SLTEAS had prior possession and that the occupation by Nuñez and others was by means of strategy and stealth. The MeTC ordered the defendants to vacate, pay monthly rentals, attorney's fees, and costs. The Regional Trial Court (RTC) Manila affirmed the MeTC decision. The Court of Appeals (CA) dismissed Nuñez's petition for review, finding that the amended complaint sufficiently alleged a cause of action for forcible entry and that the one-year prescriptive period should be counted from SLTEAS's discovery of the illegal entry in 2003 due to stealth. The Petition: Nuñez filed a Petition for Review on Certiorari with the Supreme Court, questioning the jurisdiction of the courts due to the alleged absence of forcible entry elements and a question of ownership, and arguing that he should not vacate due to an existing lease contract.
Issue(s)
Whether the Metropolitan Trial Court (MeTC) had jurisdiction over the forcible entry case. Whether the elements of forcible entry were sufficiently alleged in the amended complaint and whether the one-year prescriptive period for filing a forcible entry case was correctly reckoned. Whether petitioner Nuñez should be ordered to vacate the premises despite an alleged existing lease contract.
Ruling
The petition is denied for lack of merit. The Supreme Court affirmed the decision of the Court of Appeals, upholding the jurisdiction of the MeTC and ordering the petitioner to vacate the premises.
Ratio Decidendi
On the jurisdiction of the MeTC: The Court reiterated that ejectment cases fall within the original and exclusive jurisdiction of first-level courts. Jurisdiction over the subject matter is determined by the allegations in the complaint and the character of the relief sought, not by the defenses raised. The amended complaint sufficiently alleged prior possession by SLTEAS and dispossession by means of stealth and strategy, thus establishing a cause of action for forcible entry and conferring jurisdiction upon the MeTC. The Court emphasized that jurisdiction cannot be made to depend on the defenses set up in the answer or in a motion to dismiss. On the elements of forcible entry and the prescriptive period: The Court found that SLTEAS's amended complaint sufficiently alleged the elements of forcible entry. It stated that SLTEAS, as the registered owner, had prior possession through its representatives and predecessors-in-interest, exercising attributes of ownership. The occupation by Nuñez and others was by means of stealth and strategy, discovered in October 2003. The Court clarified that in cases of entry by stealth, the one-year prescriptive period is counted from the time the plaintiff learned of the dispossession, not from the date of actual entry. The Court also noted that Nuñez's claim of prior demand in 1996 was not presented before the MeTC and was raised for the first time on appeal, thus it could not be considered. On the alleged lease contract: The Court held that the issue of ownership or the existence of a lease contract is inappropriate in an ejectment case, which is a summary action to protect possession. Even if a lease contract existed, SLTEAS's alleged lack of knowledge and the failure to register it could not bind SLTEAS. The Court also pointed out that Nuñez failed to present proof of his lessor's title or SLTEAS's prior knowledge of the lease, and his reliance on Article 1676 of the Civil Code was misplaced in the context of a forcible entry case. The Court concluded that Nuñez's assertion of a lease contract did not oust the MeTC of its summary jurisdiction.
Main Doctrine
The jurisdiction of first-level courts over ejectment cases is determined by the allegations in the complaint and the character of the relief sought, irrespective of the defenses raised. In forcible entry cases, the requisites for jurisdiction are: (a) allegation of prior physical possession, (b) assertion of dispossession by force, intimidation, threat, strategy, or stealth, and (c) filing within one year from the time the owner or legal possessor learned of the deprivation. When entry is through stealth, the one-year period is counted from the time of knowledge.