Romullo v. Samahang Magkakapitbahay
REITERATIONFacts
The Antecedents: Respondent Samahang Magkakapitbahay ng Bayaniihan Compound Homeowners Association, Inc. (Association) secured a loan for the purchase of Bayanihan Compound under the Community Mortgage Program (CMP). The land was to be distributed to its members/beneficiaries. Petitioners, members/beneficiaries, refused to pay their monthly dues, legal fees, deposits, and amortizations for their lot allocations. Consequently, the Association expelled petitioners as members and disqualified them as beneficiaries, approving their substitution. Despite notice, petitioners continued to occupy their lots and refused to execute waivers. Conciliation at the barangay level failed. The Association then demanded petitioners vacate the premises, which they failed to do. The Association filed an ejectment case against petitioners. Procedural History: The Metropolitan Trial Court (MeTC) dismissed the Association's complaint for lack of jurisdiction, citing a pending case before the Housing and Land Use Regulatory Board (HLURB) involving the same parties and issues. The Regional Trial Court (RTC) reversed the MeTC decision, declaring the Association the lawful possessor and ordering petitioners to vacate, pay monthly compensation, and attorney's fees. The Court of Appeals (CA) affirmed the RTC's decision, holding that the MeTC had jurisdiction over the unlawful detainer case. Petitioners' motions for reconsideration were denied. The Petition: Petitioners filed a Petition for Certiorari under Rule 65, assailing the CA's decision for allegedly committing reversible error in holding that the lower court had jurisdiction and in not sustaining petitioners' argument regarding the pendency of the HLURB case (litis pendentia/prejudicial question).
Issue(s)
Whether or not the Court of Appeals committed a reversible error in holding that the lower court had jurisdiction to try the instant case. Whether or not the Honorable Court of Appeals erred in not sustaining petitioners' argument that the ruling of the RTC must be set aside due to the pendency of a case before the HLURB involving the same parties and issues.
Ruling
The petition is bereft of merit. The Court dismissed the petition and affirmed the Court of Appeals Decision dated August 22, 2007.
Ratio Decidendi
On the issue of jurisdiction: The Court reiterated the settled rule that jurisdiction in ejectment cases is determined by the allegations pleaded in the complaint and cannot depend on the defenses set up by the defendant. An action for unlawful detainer requires specific elements: (1) initial possession by contract or tolerance; (2) subsequent illegal possession upon termination of the right to possess; (3) continued possession depriving the plaintiff of enjoyment; and (4) institution of the complaint within one year from the last demand. The Court found that the Association's complaint sufficiently alleged these elements, establishing a cause of action for unlawful detainer and conferring jurisdiction on the MeTC. The CA's findings, which were based on the complaint's assertions, were accorded respect. On the issue of litis pendentia/prejudicial question: The Court rejected petitioners' contention that the RTC and CA erred in not dismissing the complaint due to the pending HLURB case. The requisites for litis pendentia are identity of parties, identity of rights asserted and relief prayed for, and identity of the two cases such that judgment in one would be res judicata in the other. The Court found that while there was an identity of parties, the issues, causes of action, and reliefs prayed for in the HLURB case (reinstatement as members, accounting, annulment of board resolutions) were different from those in the ejectment case (physical possession of lots). Therefore, not all elements of litis pendentia were present. The HLURB case involved internal membership disputes and corporate governance, while the ejectment case concerned the right to physical possession of the lots due to non-payment of dues.
Main Doctrine
Jurisdiction in ejectment cases is determined by the allegations in the complaint, not by the defenses raised by the defendant. The pendency of an administrative case before the HLURB does not necessarily suspend ejectment proceedings if the issues and reliefs prayed for are different.