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LOURDES DELA CRUZ v. CA

FACTS:

Lourdes Dela Cruz was a lessee of a lot owned by the Reyes family and had been paying rent for over 40 years. A fire destroyed her dwelling in 1989, but she and other tenants rebuilt their houses on the lot. The Reyes family verbally demanded for the tenants to vacate, but the tenants did not comply. In 1994, petitioner received a written demand to vacate but refused to leave. With no court proceedings initiated by the Reyes family, they sold the lot to respondent Melba Tan Te in 1996. Despite the sale, Dela Cruz did not give up the lot even after a written demand to relinquish the premises. Respondent then initiated conciliation proceedings, but Dela Cruz countered with an unconscionable offer for her house. Consequently, respondent filed an ejectment complaint with damages before the Manila Metropolitan Trial Court (MeTC). The MeTC ruled in favor of respondent, but the Regional Trial Court (RTC) set aside the decision, believing that the suit should have been filed within the one-year prescriptive period. The Court of Appeals (CA) reversed the RTC's decision and reinstated the MeTC's ruling. Dela Cruz filed a petition for review on certiorari before the Supreme Court.

ISSUES:

  1. Whether the Manila RTC or the Manila MeTC has jurisdiction over the ejectment suit

  2. Whether respondent is entitled to the ejectment of petitioner from the premises

  3. Whether the complaint falls under the jurisdiction of the MeTC or the RTC.

  4. Whether the complaint should be dismissed for lack of jurisdiction.

  5. Whether or not the Metropolitan Trial Court (MeTC) has jurisdiction over the ejectment complaint.

  6. Whether or not the complaint is one for unlawful detainer.

  7. Whether or not the action is properly an unlawful detainer case falling under the jurisdiction of the Manila MeTC.

  8. Whether or not the RTC has jurisdiction over the complaint after the one-year period for filing an ejectment suit has elapsed.

  9. Whether or not the issue of the validity of the ordinance can be raised before the Court of Appeals.

  10. Whether or not the intended expropriation of respondent's lot affects the resolution of the present petition.

RULING:

  1. The petition is bereft of merit. The Manila RTC has jurisdiction over the ejectment suit. The respondent is entitled to the ejectment of the petitioner from the premises.

  2. The nature of the action and the court that has jurisdiction over the case are determined by the allegations in the complaint. The designation or caption is not controlling. In this case, the allegations in the complaint show that prior to the sale, the plaintiff was in possession and control of the subject lot but were deprived of said possession when the defendant entered and occupied the same lot. These circumstances imply that there was prior physical possession and can make up a forcible entry complaint.

  3. The general rule is that when tenancy is averred by way of defense and is proved to be the real issue, the case should be dismissed for lack of jurisdiction as it should properly be filed with the Court of Agrarian Relations. However, the allegations in the complaint in this case are vague and do not clearly reveal the nature of the action for ejectment. It is unclear whether the defense of tenancy is the real issue. Therefore, the issue of whether the complaint should be dismissed for lack of jurisdiction cannot be resolved at this point.

  4. The MeTC has jurisdiction over the ejectment complaint. Even though the defense of lack of jurisdiction was raised in the answer, it was considered as an exception due to the special circumstances present in this case. The fact that the petitioner was a tenant of the predecessors-in-interest of the respondent is material to the determination of jurisdiction. Additionally, the ejectment suit was filed more than nine years ago, and dismissing the complaint would be a blow to the effective dispensation of justice. Section 6, Rule 1 of the Rules of Court allows the court to construe procedural rules in a liberal manner to promote just, speedy, and inexpensive disposition of actions and proceedings.

  5. The complaint is one for unlawful detainer. It was admitted that the petitioner was a lessee of the former owners of the lot, and when the lot was sold to the respondent, the rights of the former owners were transferred to the respondent. The petitioner continued to occupy the lot without consent after her contract of lease was terminated due to a fire. The respondent tolerated the petitioner's stay until she decided to eject the petitioner by sending several demands. Since the action was filed within one year from the last demand, it falls within the period for unlawful detainer.

  6. The action is properly an unlawful detainer case falling under the jurisdiction of the Manila MeTC. Petitioner's possession after she intruded into the lot after the fire was by tolerance or leniency of the owner.

  7. Even if the RTC has jurisdiction over the complaint, the Court suspends its rules in order to render efficient, effective, and expeditious justice considering the long pendency of the ejectment suit.

  8. The issue of the validity of the ordinance cannot be raised before the Court of Appeals since it was raised for the first time in the said court and is proscribed.

  9. Even if the issue of the intended expropriation of respondent's lot is entertained, it will not affect the resolution of the present petition. The issue can be raised in the appropriate legal proceeding, and the intended expropriation might not even be implemented given that available funds for the project still need to be located.

PRINCIPLES:

  • Jurisdiction is the power or capacity given by the law to a court or tribunal to entertain, hear and determine certain controversies.

  • The jurisdiction over ejectment proceedings (accion interdictal) is lodged with the first level courts, specifically the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts.

  • There are two kinds of ejectment proceedings: (1) forcible entry, which requires the prior physical possession of the property and a deprivation of possession by force, intimidation, threat, strategy, or stealth; and (2) unlawful detainer, which involves the withholding of possession of the subject property after the expiration or termination of the right to possess.

  • The RTC has exclusive original jurisdiction over actions which involve the title to or possession of real property, except for actions for forcible entry and unlawful detainer.

  • Actions for recovery of possession of real property that fall under the jurisdiction of the RTC include the plenary action for the recovery of the real right of possession and an action for the recovery of ownership. These actions are governed by the regular rules of procedure and adjudication takes a longer period than the summary ejectment suit.

  • The allegations in the complaint determine the nature of the action and the court that has jurisdiction over the case.

  • The designation or caption of the complaint is not controlling.

  • The defense of tenancy may affect the jurisdiction of the court.

  • The defense of tenancy should be properly filed with the Court of Agrarian Relations.

  • Jurisdiction is based on the allegations in the initiatory pleading, and the defenses in the answer are irrelevant and immaterial in its determination. However, there are exceptions when special and unique circumstances are present.

  • The court has the power to construe procedural rules in a liberal manner to promote just, speedy, and inexpensive disposition of actions and proceedings.

  • Ejectment complaints based on possession by tolerance of the owner are considered as unlawful detainer cases.

  • The rules of procedure should be viewed as mere tools designed to facilitate the attainment of justice. Their strict and rigid application that frustrates substantial justice must be avoided.

  • Rules must not be applied rigidly so as not to override substantial justice.

  • The RTC has the authority to try a case on the merits if the municipal trial court initially dismissed the case for lack of jurisdiction and the RTC has jurisdiction over the case.

  • The Court has the power to suspend or disregard its rules under special or compelling circumstances.

  • At the heart of every ejectment suit is the issue of who is entitled to physical possession of the property.

  • Issues raised for the first time before the Court of Appeals are proscribed.

  • The validity of an ordinance can be raised in the appropriate legal proceeding.

  • The intended expropriation of a property does not necessarily affect the resolution of a petition if it has not been implemented and there is still a need to locate available funds for the project.