Facts:

The case involved Baby Arlene Larano (petitioner) against Spouses Alfredo and Rafaela Calendacion (respondents), with a decision rendered by the Supreme Court on June 19, 2007, pertaining to a petition for unlawful detainer. Petitioner held ownership of a parcel of riceland situated in Barangay Daniw, Municipality of Victoria, Laguna, which was covered by Transfer Certificate of Title No. 175241. On September 14, 1998, the petitioner and respondents executed a Contract to Sell, allowing the respondents to purchase a 50,000-square meter portion of the riceland at a total price of P5 million, accompanied by a down payment of P500,000 and nine installment payments of P500,000 until September 2001. Possession of the land was transferred to the respondents, contingent upon their accounting and delivery of harvests to the petitioner. However, respondents defaulted on payments and failed to provide the required harvest deliveries. Following a demand letter issued on March 7, 2000, the

...

Facts:

Parties Involved

• Petitioner: Baby Arlene Larano, owner of a parcel of riceland in Barangay Daniw, Municipality of Victoria, Laguna.
• Respondents: Spouses Alfredo Calendacion and Rafaela T. Calendacion, who entered into a contract to purchase a portion of the riceland.

Transaction and Contract to Sell

• On September 14, 1998, the petitioner and respondents executed a Contract to Sell whereby the respondents agreed to purchase a 50,000‑square meter portion of the petitioner’s riceland for P5 million.
• The agreed terms included a down payment of P500,000.00 and the balance payable in nine installments of P500,000.00 each, to be completed by September 2001.
• Possession of the riceland was transferred to the respondents pending full payment, subject to the condition that the respondents would account for and deliver the harvest from the riceland to the petitioner.

Breach and Default by Respondents

• Respondents failed to pay the required installments.
• They also did not account for or deliver the harvest from the riceland as specified in the contract.
• Consequently, on March 7, 2000, the petitioner issued a demand letter ordering the respondents to vacate the property within 10 days from receipt.

Initiation of Legal Proceedings

• On April 5, 2000, after the demand went unheeded, the petitioner filed a Complaint for Unlawful Detainer before the Municipal Trial Court (MTC) in Victoria, Laguna (Civil Case No. 826).
• The complaint sought:
• An order directing the respondents to vacate the property.
• Payment of P400,000.00 per year from September 1998 until the property was vacated (as reasonable compensation for the use of the property).
• P120,000.00 as attorney’s fees and P50,000.00 for litigation expenses.

Proceedings in Lower Courts

• The respondents filed an Answer on April 26, 2000, wherein they admitted the contract’s execution but contested that it embodied the full agreement between the parties.
• They argued that:
• The period for payment had not lapsed, as the three‑year period was still in effect.
• The complaint failed to allege that a demand to pay and vacate was made, casting doubts on the MTC’s jurisdiction.
• On August 2, 2001, the MTC rendered a Decision ordering:
• Immediate vacation of the premises by the respondents.
• Payment of P365,000.00 as reasonable compensation for the property’s use.
• Payment of attorney’s fees and litigation expenses totaling P25,000.00.
• Respondents appealed to the Regional Trial Court (RTC) where, on December 3, 2001, the RTC modified the MTC decision by:
• Affirming the eviction order.
• Ordering compensation of P400,000.00 per year from 1999 until actual vacation of the property.

Petition for Review and Court of Appeals (CA) Proceedings

• The respondents filed a Petition for Review before the Court of Appeals (CA).
• The petitioner failed to file a comment on the CA Resolution (May 8, 2002), thereby waiving the opportunity to raise certain objections.
• On May 13, 2003, the CA rendered a Decision which:
• Set aside the RTC Decision.
• Dismissed the complaint for unlawful detainer.
• Held that the proceedings in the MTC were void for lack of jurisdiction since the case involved issues extending beyond mere possession—namely, the interpretation and enforcement (or rescission) of the Contract to Sell.

Contentions of the Parties on Appeal

• Petitioner’s Arguments:
• Argued that the CA erred in giving due course to a non‑verified petition for review as mandated by the Rules.
• Contended that the CA improperly recharacterized the case from an unlawful detainer suit to one involving specific performance/rescission of the contract by relying on extraneous allegations.
• Respondents’ Arguments:
• Claimed that verification is a mere formality and that the petitioner’s failure to file a comment amounted to a waiver of any objection regarding the verification defect.
• Maintained that the CA correctly classified the case as a contractual dispute (one incapable of pecuniary estimation) rather than a traditional unlawful detainer suit.

Issue:

Jurisdictional Issue

• Whether the complaint filed by the petitioner qualifies as an unlawful detainer suit given that it primarily alleged a breach of the Contract to Sell rather than a clear case of deprivation of rightful possession.

Sufficiency of the Demand and Jurisdiction Requirements

• Whether the petitioner’s failure to include the requisite demand to pay or to comply with the contractual conditions (including a proper period to vacate as provided under the law) deprived the MTC of jurisdiction over the case.

Verification of the Petition for Review

• Whether the lack of verification in the petition for review should have led to its dismissal, and if such deficiency was fatal given that the petitioner had waived any such objection by failing to file a comment.

Characterization of the Case

• Whether the case should be treated as one involving mere unlawful detainer (a possession problem) or as one involving contractual interpretation, enforcement, or rescission (which falls outside the jurisdiction of the MTC).

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)