Title
Tagalog vs. Vda. de Gonzales
Case
G.R. No. 201286
Decision Date
Jul 18, 2014
The Supreme Court of the Philippines held that a Regional Trial Court's lack of jurisdiction over land possession cases invalidates its decisions.
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Case Digest (G.R. No. 201286)

Facts:

  • The case concerns Lot No. 1595-A, a 27,551 square meter parcel of land in Buanoy, Balamban, Cebu, covered by TCT No. T-57604.
  • On February 5, 2003, respondents filed a complaint against petitioner Inocencia Tagalog for Recovery of Possession, Preliminary Mandatory Injunction, Damages, and Attorney's Fees in the RTC of Toledo City, Cebu, Branch 29.
  • Respondents claimed co-ownership of the land and alleged that Tagalog occupied a portion as a lessee under a verbal contract, paying rent monthly.
  • After a typhoon damaged Tagalog's house, she stopped paying rent and vacated the premises.
  • Respondents demanded Tagalog remove debris and vacate the land, asserting the lease was terminated, but Tagalog refused, claiming the lease was still valid.
  • In January 2003, Tagalog began constructing a two-storey house on the property without consent or a building permit.
  • Respondents reported the construction to local authorities, but Tagalog continued.
  • The RTC ruled in favor of the respondents on May 5, 2008, ordering Tagalog to vacate and pay damages.
  • Tagalog's motion for reconsideration was denied, leading her to appeal to the Court of Appeals, which dismissed her appeal on May 12, 2011, for failure to file a required brief.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Inocencia Tagalog, granting her petition and setting aside the resolutions of the Court of Appeals.
  • The case was dismissed without pre...(Unlock)

Ratio:

  • The Supreme Court determined that the RTC lacked jurisdiction, as the case was essentially one of unlawful detainer, which should have been filed in the Municipal Trial Court (MTC).
  • The Court explained that jurisdiction is determined by the nature of the action, which in this case involved only the issue of physical possession.
  • The definition of unlawful detainer was cited, emphasizing it pertains to withholding possession after a lease's expiration.
  • Since the complaint wa...continue reading

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