View full case

SPS. VICENTE DIONISIO v. WILFREDO LINSANGAN

FACTS:

The case involves the ownership and possession of agricultural lands in San Rafael, Bulacan. Cruz, the original owner, allowed Romualdo San Mateo and his widow, Emiliana, to stay on the property as tenants. After Romualdo's death, Emiliana continued to occupy the land with Cruz's permission, on the condition that she would vacate it upon demand. In September 1989, the Dionisios purchased the property from Cruz. In April 2002, they discovered that Emiliana had left the property and it was now occupied by Wilfredo Linsangan under a "Kasunduan ng Bilihan ng Karapatan" dated April 7, 1977. The Dionisios demanded that Wilfredo vacate the land, but he refused. The Dionisios then filed an eviction suit against Wilfredo before the Municipal Trial Court (MTC) of San Rafael, Bulacan. The MTC ruled in favor of the Dionisios, ordering Wilfredo to vacate the land and pay compensation and attorney's fees. However, on appeal, the Court of Appeals (CA) reversed the decision and ordered the dismissal of the Dionisios' action, stating that the amendment made by the Dionisios effectively changed their cause of action and fell outside the jurisdiction of the MTC. The CA also noted that the jurisdiction over the action could not be determined without the assessed value of the property being alleged in the complaint.

ISSUES:

  1. Whether or not the Dionisios' amendment of their complaint effectively changed their cause of action from one of ejectment to one of recovery of possession.

  2. Whether or not the MTC had jurisdiction over the action before it.

RULING:

  1. Amendment of Complaint: The amendment of the complaint by the Dionisios did not change the cause of action from one of ejectment to one of recovery of possession. Both the original and amended complaints required Wilfredo to defend his possession based on the allegation that he stayed on the land out of the owner's mere tolerance and that the owner had demanded that he leave. Thus, the statute of limitations resumed its run but did not commence a new filing date.

  2. Jurisdiction of the MTC: The MTC had jurisdiction over the action as it was determined by the allegations of the complaint. Wilfredo failed to substantiate his claim that he was a tenant. The action is characterized as one for unlawful detainer based on the allegations that the Dionisios tolerated Emiliana's (and subsequently Wilfredo’s) stay on the land and demanded that they leave within a year of filing the complaint.

PRINCIPLES:

  1. Amendment of Complaint and Cause of Action: An amendment that changes the plaintiff’s cause of action constitutes a new complaint. An amendment that merely supplements facts without altering the cause of action does not reset the filing date.

  2. Jurisdiction Based on Allegations: The court's jurisdiction is determined by the allegations in the complaint, not the defense.

  3. Elements of Unlawful Detainer: An action for unlawful detainer must allege initial possession by tolerance or contract, illegal possession after a demand to vacate, continued possession depriving the plaintiff, and filing of the suit within one year from the last demand.

  4. Doctrine on Possession by Tolerance: Possession initially by tolerance implies an understanding that such possession is subject to termination upon demand by the owner.