Facts:

In the case of Balibago Faith Baptist Church, Inc. and Philippine Baptist S.B.C., Inc. vs. Faith in Christ Jesus Baptist Church, Inc. and Reynaldo Galvan, filed under G.R. No. 191527, a petition for review was initiated due to a disagreement regarding the rightful possession of a parcel of land in Angeles City, which was registered as Lot 3, Blk. 35 of (LRC) PCS-2364. The case began with a complaint for unlawful detainer and damages filed by the petitioners, Balibago Faith Baptist Church, Inc. (BFBC) and Philippine Baptist S.B.C., Inc. (PBSBC), against the respondents, Faith in Christ Jesus Baptist Church, Inc. (FCJBC) and Reynaldo Galvan. The controversy stemmed from a contract of loan dated March 7, 1990, between PBSBC and BFBC that allowed BFBC to purchase the subject property, where BFBC carried out its religious activities.

Galvan, after attending services at BFBC's property, founded FCJBC, which later occupied the contested land. A letter from the Luzon Convention of S

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Facts:

Background and Initiation of the Case

• The case arose from a Complaint for unlawful detainer and damages filed by petitioners Balibago Faith Baptist Church, Inc. (BFBC) and Philippine Baptist S.B.C., Inc. (PBSBC) against respondents Faith in Christ Jesus Baptist Church, Inc. (FCJBC) and Reynaldo Galvan.
• The subject matter involves a parcel of land with improvements known as Lot 3, Blk. 35 of (LRC) PCS-2364, covered by Transfer Certificate of Title No. 82587, located at 35-3 Sarita St., Diamond Subdivision, Balibago, Angeles City, which is owned by PBSBC.

Transactions and Possession History

• On March 7, 1990, a contract of simple loan was executed between PBSBC and BFBC, enabling BFBC to purchase the subject property.
• BFBC took possession of the subject property and conducted their religious activities there.
• While BFBC was in possession, Reynaldo Galvan and his companions joined the religious services held on the premises, eventually leading to Galvan’s interest in the property.

Development of the Dispute

• Galvan proceeded to form and incorporate FCJBC and took control of the subject property, an act that was initially perceived as a takeover of the property from BFBC.
• The Luzon Convention of Southern Baptist Churches, Inc. (LCSBC) intervened by issuing a letter dated September 5, 2001, which upheld BFBC’s right over the property and recognized its pastor, Rev. Rolando T. Santos, as the legitimate pastor.

Procedural Maneuvers and Subsequent Actions

• Despite the position of BFBC as affirmed by LCSBC and its demand letter (dated September 4, 2002) requiring FCJBC to vacate the property and pay compensation, FCJBC continued to occupy the property.
• BFBC and PBSBC subsequently filed the Complaint in the Municipal Trial Court (MTC), Branch 2, Angeles City, alleging unlawful detainer and seeking ejectment of FCJBC.
• FCJBC and Galvan answered the complaint by asserting that their organization evolved from an earlier entity and that their occupancy was based on historical acquisition and payment of installments.
• The case was first ruled by the MTC on February 9, 2004, which found the action to be one of forcible entry rather than unlawful detainer, ordering FCJBC to vacate the premises and pay attorney’s fees and costs.
• The Regional Trial Court (RTC) affirmed the MTC decision on April 19, 2006; FCJBC’s subsequent motion for reconsideration was denied.
• FCJBC filed a petition for review on certiorari before the Court of Appeals, which on March 5, 2010, reversed the lower court decision by dismissing the complaint.

Allegations and Factual Contentions

• The complaint contained detailed allegations regarding the subject property, the contractual relationship between PBSBC and BFBC, and the subsequent entry by Reynaldo Galvan and FCJBC.
• Specific paragraphs in the complaint indicated:
• BFBC commenced possession after the contract of loan, holding religious activities at the property.
• Galvan’s entry and the formation of FCJBC were characterized as an unauthorized takeover, devoid of BFBC’s or PBSBC’s consent.
• Despite BFBC’s demand for vacating the premises and payment of compensation, defendants remained in possession.
• The Complaint, however, failed to expressly allege that FCJBC’s entry was preceded by any lawful possession by the defendants or specify how and when the actual dispossession occurred.

Issue:

Jurisdictional and Characterization Issue

• Whether the Court of Appeals erred in dismissing the complaint on the ground that the Municipal Trial Court (MTC) lacked jurisdiction over the case.
• Whether the characterization of the case as one of unlawful detainer was proper given the factual allegations regarding the entry and possession of the subject property.

Raising of Unpresented Issues

• Whether it was erroneous for the Court of Appeals to raise issues concerning the sufficiency of the complaint and the jurisdiction of the MTC that were not originally raised by the parties.

Decision on the Merits

• Whether the Court of Appeals erred in dismissing the complaint instead of deciding the case on its merits in light of Section 8, Rule 140 of the Rules of Court.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)