FACTS:

Telesforo Julao filed two applications with the Department of Environment and Natural Resources (DENR) for townsite sales. One of the applications, TSA No. V-2132, resulted in the issuance of Original Certificate of Title (OCT) No. P-2446 in favor of Telesforo's heirs. The other application, TSA No. V-6667, was dropped from the records by the DENR. Solito Julao, brother of Telesforo, executed a Deed of Transfer of Rights, transferring his hereditary share in the property covered by TSA No. V-6667 to respondent spouses Alejandro and Morenita De Jesus. Petitioners Anita Julao vda. De Enriquez, Sonia J. Tolentino, and Roderick Julao, claiming to be the true heirs of Telesforo, filed a Complaint for Recovery of Possession of Real Property against respondent spouses. They alleged that respondent spouses' house encroached on 70 square meters of the subject property covered by OCT No. P-2446. The trial court ruled in favor of petitioners, but the Court of Appeals reversed the decision, stating that the complaint was dismissible for failure to identify the property sought to be recovered and lack of jurisdiction. Petitioners filed a Petition for Review on Certiorari before the Supreme Court, raising several errors committed by the Court of Appeals.

ISSUES:

1. Whether petitioners failed to prove the identity of the property in question.

2. Whether the trial court acquired jurisdiction over the complaint.

RULING:

1. The Court of Appeals committed a reversible error in ruling that petitioners failed to prove the identity of the property in question.

2. The Court of Appeals committed a reversible error in ruling that the trial court did not acquire jurisdiction over the complaint.

PRINCIPLES:

• Jurisdiction over the subject matter is determined by the material allegations of the complaint and cannot be acquired through or waived by any act or omission of the parties. It also cannot be cured by their silence, acquiescence, or even express consent.