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BALIBAGO FAITH BAPTIST CHURCH v. FAITH IN CHRIST JESUS BAPTIST CHURCH

FACTS:

The Balibago Faith Baptist Church, Inc. (BFBC) and Philippine Baptist S.B.C., Inc. (PBSBC) borrowed money from PBSBC to purchase a parcel of land which they used for religious activities. They subsequently took possession of the property and conducted their religious services there. Meanwhile, Reynaldo Galvan and his companions started attending BFBC's religious activities and eventually formed and incorporated the Faith in Christ Jesus Baptist Church, Inc. (FCJBC). FCJBC took control of the subject property, refusing to vacate despite demands from BFBC and PBSBC. As a result, BFBC and PBSBC filed a complaint for unlawful detainer and damages against FCJBC and Galvan before the Municipal Trial Court (MTC). FCJBC and Galvan, in their Answer, claimed that FCJBC had been in existence since 1984 and occupied the subject property after availing a loan for its purchase. They also asserted that BFBC was formed after a misunderstanding within FCJBC. The MTC ruled in favor of BFBC, but the RTC and Court of Appeals later reversed the decision, dismissing the complaint for unlawful detainer. BFBC and PBSBC then filed a petition for review before the Supreme Court.

ISSUES:

  1. Whether the complaint filed by the plaintiff is for unlawful detainer or forcible entry.

  2. Whether the complaint sufficiently alleges a cause of action for unlawful detainer.

  3. Whether the case should be treated as unlawful detainer or forcible entry.

  4. Whether the complaint sufficiently alleged how and when the dispossession took place.

  5. Whether the Municipal Trial Court (MTC) has jurisdiction over the case.

RULING:

  1. The complaint filed by the plaintiff is for unlawful detainer. Unlawful detainer is the act of withholding possession of any land or building after the expiration or termination of the right to hold possession under any contract, express or implied. On the other hand, forcible entry pertains to the possession of a property that is illegal from the beginning, and the only issue is who has the prior possession de facto.

  2. The complaint filed by the plaintiff sufficiently alleges a cause of action for unlawful detainer. To allege a cause of action for unlawful detainer, the complaint must recite the following: (1) initially, possession of property by the defendant was by contract with or by tolerance of the plaintiff; (2) eventually, such possession became illegal upon notice by the plaintiff to the defendant of the termination of the latter's right of possession; (3) thereafter, the defendant remained in possession of the property and deprived the plaintiff of the enjoyment thereof; and (4) within one year from the last demand on the defendant to vacate the property, the plaintiff instituted the complaint for ejectment.

  3. The case should be treated as forcible entry. While the allegations in the complaint contradicted the requirements for unlawful detainer, it did not sufficiently allege how and when dispossession took place, which are constitutive of forcible entry.

  4. The complaint failed to allege how and when entry was effected, thus leaving it wanting in jurisdictional grounds.

  5. The MTC has no jurisdiction over the case because the dispossession did not occur by any of the means stated in Section 1, Rule 70. The proper recourse is to file a plenary action to recover possession with the Regional Trial Court.

PRINCIPLES:

  • Unlawful detainer refers to the act of withholding possession of any land or building after the expiration or termination of the right to hold possession under any contract, express or implied. Forcible entry, on the other hand, pertains to the possession of a property that is illegal from the beginning.

  • The allegations in the complaint determine the nature of the action and the jurisdiction of the court.

  • The cause of action stated in the complaint is determined by the allegations in the body of the complaint, not by the designation or caption.

  • What determines the cause of action is the nature of the defendant's entry into the land. If the entry is illegal, the cause of action is forcible entry. If the entry is legal but possession later becomes illegal, the cause of action is unlawful detainer.

  • The complaint must embody a statement of facts that brings the party clearly within the class of cases for which the law provides a remedy in ejectment proceedings.

  • The complaint for unlawful detainer must show enough on its face to establish the court's jurisdiction without resorting to parol testimony.

  • In unlawful detainer, the possession of the defendant was originally legal and its possession was tolerated or permitted by the owner through an express or implied contract.

  • In an unlawful detainer case, the defendant's possession becomes illegal only upon the plaintiffs demand for the defendant to vacate the property and the defendant's subsequent refusal.

  • Forcible entry does not necessarily require the use of force; the act of going on the property and excluding the lawful possessor therefrom implies the exertion of force over the property.

  • A court's jurisdiction may be raised at any stage of the proceedings, even on appeal. Lack of jurisdiction affects the authority of the court to take cognizance of and render judgment on the action. A void judgment for want of jurisdiction is no judgment at all.