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AMADA C. ZACARIAS v. VICTORIA ANACAY

FACTS:

The present controversy began with a complaint for Ejectment with Damages/Unlawful Detainer filed by Amada Zacarias against Victoria Anacay and members of her household. Zacarias asserted ownership of a parcel of land covered by Tax Declaration No. 18-026-01182. The Municipal Circuit Trial Court (MCTC) dismissed the complaint, stating that it lacked jurisdiction since the essential elements of unlawful detainer were not adequately stated. On appeal, the Regional Trial Court (RTC) reversed the MCTC's decision, ordering Anacay and the other respondents to vacate the property and pay damages. The RTC decision became final and executory due to the failure of the respondents to file a notice of appeal. However, the respondents lodged a petition for certiorari with the Court of Appeals (CA) which accepted their petition. The CA determined that the MCTC lacked jurisdiction and ruled that Zacarias had chosen the wrong remedy. Zacarias then filed a petition for review before the Supreme Court, asserting that the CA had erred in nullifying the RTC decision. The Supreme Court, after careful consideration, found no grave abuse of discretion or reversible error committed by the CA. The allegations presented in Zacarias' complaint established a case for forcible entry but not for unlawful detainer.

ISSUES:

  1. Whether the complaint sufficiently alleged a cause of action for unlawful detainer.

  2. Whether the MCTC had jurisdiction over the case.

  3. Whether the complaint in this case sufficiently alleged facts constitutive of forcible entry or unlawful detainer, as required for the court to have jurisdiction over the case.

  4. Whether the Court of Appeals erred in nullifying a final and executory judgment of the Regional Trial Court.

RULING:

  1. The complaint failed to allege a cause of action for unlawful detainer as it did not describe possession by the respondents being initially legal or tolerated by the petitioner and which became illegal upon termination by the petitioner of such lawful possession. The possession of the defendant in unlawful detainer should be originally legal but became illegal due to the expiration or termination of the right to possess.

  2. Since the complaint failed to satisfy the jurisdictional requirement of a valid cause for unlawful detainer, the MCTC had no jurisdiction over the case.

  3. The complaint failed to allege key jurisdictional facts constitutive of forcible entry or unlawful detainer, such as how and when entry was effected and how and when dispossession started. As a result, the Municipal Trial Court had no jurisdiction over the case. The Regional Trial Court also erred in reversing the lower court's ruling and granting the reliefs prayed for by the petitioner.

  4. The argument that the Court of Appeals erred in nullifying a final and executory judgment of the Regional Trial Court is not given much consideration. A court's lack of jurisdiction may be raised at any stage of the proceedings, even on appeal. A void judgment for want of jurisdiction has no legal effect and cannot be the source of any right or obligation.

PRINCIPLES:

  • In order for a complaint to sufficiently allege a cause of action for unlawful detainer, it must recite the following elements: (a) initially, possession of property by the defendant was by contract with or by tolerance of the plaintiff; (b) eventually, such possession became illegal upon notice by plaintiff to defendant of the termination of the latter's right of possession; (c) thereafter, the defendant remained in possession of the property and deprived the plaintiff of the enjoyment thereof; and (d) within one year from the last demand on defendant to vacate the property, the plaintiff instituted the complaint for ejectment. (Cabrera v. Getaruela)

  • The possession in unlawful detainer should be originally legal but became illegal due to the expiration or termination of the right to possess. If the possession was unlawful from the start, an action for unlawful detainer would be an improper remedy. (Valdez v. Court of Appeals)

  • The jurisdictional facts must appear on the face of the complaint in proceedings for forcible entry and unlawful detainer. When the complaint fails to aver facts constitutive of these actions, the proper remedies are either an accion publiciana or an accion reivindicatoria in the Regional Trial Court.

  • The possession sought to be recovered in unlawful detainer cases must be present right from the start of possession, while tolerance must be present right from the start to categorize a cause of action as unlawful detainer and not forcible entry.

  • Lack of jurisdiction affects the court's authority to take cognizance of and render judgment on the action. A void judgment for want of jurisdiction has no legal effect and cannot be the source of any right or obligation.

  • A decision rendered by the Court of Appeals in a petition for certiorari can be executed upon, provided it complies with the requisites for executory judgments.

  • A final and executory judgment has the force and effect of res judicata, thereby finally settling the rights of the parties.

  • A writ of execution based on a decision rendered by the Court of Appeals may be considered void if it does not comply with the requisites for executory judgments.