Tagalog v. Gonzalez
REITERATIONFacts
The Antecedents: Respondents filed a Complaint for Recovery of Possession, Preliminary Mandatory Injunction with a Prayer for a Temporary Restraining Order with Damages and Attorney’s Fees against petitioner before the Regional Trial Court (RTC). The subject matter was a parcel of land occupied by petitioner as a lessee under a verbal month-to-month lease contract. Respondents alleged that petitioner’s house was damaged by a typhoon, she stopped paying rent, and they demanded she vacate the premises to allow them to use, subdivide, and develop the land. Petitioner refused to vacate, claiming she was still a lessee. Subsequently, petitioner began constructing a two-storey cement house on the land without respondents' consent. Respondents reported this to the Municipal Engineer and Barangay Captain, but petitioner continued construction. Procedural History: The RTC ruled in favor of the respondents, ordering petitioner to vacate, deliver possession, remove structures at her expense, and pay damages and attorney's fees. The RTC reasoned that the issue of ownership was primordial and within its jurisdiction, with eviction being merely incidental. Petitioner’s motion for reconsideration was denied. On appeal, the Court of Appeals (CA) dismissed the case for petitioner's failure to file the required brief. Petitioner filed the instant petition for review on certiorari. The Petition: Petitioner contends that the RTC lacked jurisdiction over the subject matter, arguing the case was one of unlawful detainer cognizable by the Municipal Trial Court (MTC).
Issue(s)
Whether the Regional Trial Court had jurisdiction over the subject matter of the action, specifically whether the action was an unlawful detainer suit. Whether the issue of ownership was the primary issue raised by the parties, thus justifying the RTC's cognizance of the case.
Ruling
The Supreme Court granted the petition, set aside the Resolutions of the Court of Appeals, and dismissed the Civil Case filed before the RTC without prejudice to the parties seeking relief in the proper forum.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the jurisdiction of a court is determined by the allegations in the complaint. In this case, the respondents' complaint, despite being labeled as for recovery of possession and injunction, contained allegations that clearly established an unlawful detainer case. The respondents alleged that the verbal contract of lease was terminated upon expiration of the monthly contract, they demanded petitioner vacate, and petitioner refused to vacate, withholding possession unlawfully. The construction of a new house by the petitioner occurred after the termination of the lease and demand to vacate. The Court emphasized that an unlawful detainer suit is filed to recover physical possession (possession de facto) where dispossession has lasted for not more than one year, and it falls under the exclusive original jurisdiction of the Municipal Trial Court (MTC). The Court reiterated the principle that jurisdiction is conferred by law, and any judgment, order, or resolution issued without it is void and cannot be given effect. This rule applies even if the issue of jurisdiction is raised for the first time on appeal or after final judgment. Since the petitioner raised the issue of jurisdiction in her Answer, the RTC erred in not dismissing the case. The Court also noted that it is the duty of the court to dismiss an action whenever it appears that it has no jurisdiction over the subject matter, as provided under Section 2, Rule 9 of the Rules of Court. Consequently, because the RTC proceedings and decision were null and void for lack of jurisdiction, the appeal brought before the Court of Appeals, as well as the resolutions promulgated by the CA, were also without force and effect. Distinguishing from Accion Publiciana: The Court clarified that if the action were for the recovery of the right to possess (accion publiciana) and dispossession lasted for more than one year, the RTC would have jurisdiction. However, in this case, the unlawful withholding of possession lasted only for approximately three months before the complaint was filed. Furthermore, the issue of ownership was not the primary issue raised by the parties, contrary to the RTC's justification for taking cognizance of the case.
Main Doctrine
A Regional Trial Court commits reversible error when it takes cognizance of an unlawful detainer case, which falls under the exclusive original jurisdiction of the Municipal Trial Court, as the RTC's proceedings and decision in such a case are rendered void for lack of jurisdiction.