Case Summary (G.R. No. 203160)
Procedural Posture
- Barangay conciliation preceded suit; a certificate to file action was issued to respondent.
- Manila Metropolitan Trial Court (MeTC), Branch 20: plaintiff (respondent Tan Te) won; MeTC ordered petitioner to vacate, awarded monthly sums for occupancy and attorney’s fees.
- Manila Regional Trial Court (RTC), Branch 35: on appeal, the RTC reversed the MeTC, dismissed the complaint for lack of jurisdiction (concluding an accion publiciana was proper because more than one year had elapsed), and dismissed respondent’s complaint.
- Court of Appeals (CA): reversed the RTC, reinstated the MeTC judgment.
- Supreme Court: denied petitioner’s petition for review and affirmed the CA decision in toto.
Essential Facts
- Petitioner had been a rent‑paying occupant for over forty years under predecessors (the Reyes family).
- A fire in late 1989 destroyed petitioner’s dwelling; petitioner and other tenants rebuilt and reoccupied the lot thereafter. The Reyes family made verbal demands and later served written demand(s) (notably February 21, 1994). The Reyes did not initiate court proceedings.
- The Reyes sold the lot to respondent on November 26, 1996; respondent made written demand to vacate on January 14, 1997. After failed settlement attempts and barangay conciliation, respondent filed an ejectment action in the MeTC on September 8, 1997.
- Petitioner’s answer alleged, among other defenses, tenancy protected by P.D. 20, the lease as a legal encumbrance binding successors‑in‑interest, and that the MeTC lacked jurisdiction because forcible entry had occurred more than one year earlier.
Issues Presented by Petitioner
- Whether the Court of Appeals exceeded the issues of the case and departed from the trial court’s scope.
- Whether the Court of Appeals erred in reversing the RTC and reinstating the MeTC decision, contending the MeTC decision was contradicted by the evidence.
Legal Framework on Jurisdiction (as applied)
- B.P. Blg. 129, Section 33: metropolitan/municipal trial courts have exclusive original jurisdiction over forcible entry and unlawful detainer cases (ejectment in summary form), subject to the proviso about ownership issues.
- B.P. Blg. 129, Section 19: RTCs have exclusive original jurisdiction in civil actions involving title to or possession of real property (except forcible entry and unlawful detainer). Actions properly cognizable by RTC include accion publiciana (plenary recovery of possession after prolonged dispossession) and accion reivindicatoria (recovery of ownership).
- Rule 70 (1997 Rules): distinguishes forcible entry (detentacion) — requires prior physical possession, deprivation by force/intimidation/strategy/stealth, and filing within one year from discovery — from unlawful detainer (desahucio) — requires contractual tenancy, termination/expiration of the right to possess, demand, and filing within one year from last demand.
- Rule 45: limits Supreme Court review of findings of fact by the CA, but exceptions exist where factual findings of the CA and RTC conflict or where the CA purportedly went beyond the issues.
Court’s Approach to the Jurisdictional Conflict
- The central threshold question was whether the MeTC (summary ejectment) or the RTC (plenary action) had jurisdiction. Normally, the nature of the action is determined by the allegations in the complaint; defenses in the answer are ordinarily immaterial to that determination.
- The complaint contained mixed and somewhat vague allegations: it alleged prior possession by the Reyes, an alleged surreptitious intrusion by petitioner (suggesting forcible entry), but also alleged multiple written demands and continued refusal to vacate (suggesting unlawful detainer).
- The RTC characterized the matter as an accion publiciana because the Reyes allegedly learned of the intrusion as early as February 21, 1994 and no ejectment suit was filed within one year; the RTC thus held the MeTC lacked jurisdiction.
- The Supreme Court, however, applied the recognized exception to the general rule, treating judicial admissions in petitioner’s answer (admitting long‑standing tenancy) and the totality of circumstances (including petitioner’s status as a long‑time lessee and the written demand of January 14, 1997) as material to determining the nature of the action.
Rationale for Treating the Action as Unlawful Detainer
- Petitioner’s admission that she was a rent‑paying lessee of the Reyes for decades was a judicial admission and relevant to the jurisdictional analysis. That admission tended to establish an original legal possession as lessee and thus supported characterization as unlawful detainer rather than forcible entry.
- The doctrine of “possession by tolerance” was applied: after the fire the lessor(s) considered leases terminated, but the lessor(s) tolerated petitioner’s continued occupancy for a period, creating a possessory status analogous to a tenant who must vacate upon demand. Jurisprudence cited in the decision (e.g., Lucido, Racaza, Calubayan) recognizes that where the owner tolerates continued occupancy, the one‑year period for detainer runs from the last demand to vacate.
- Because respondent’s final written demand was on January 14, 1997 and the MeTC complaint was filed September 8, 1997, the action was within the one‑year prescriptive period for an unlawful detainer suit. Consequently, the MeTC properly exercised jurisdiction.
Consideration of Procedural Fairness and Rule Relaxation
- The Court emphasized liberal construction of procedural rules to promote just, speedy, and inexpensive disposition (citing the power to relax rules and related precedents). Given the nine years of litigation, the Court preferred to avoid technical dismissals that would restart proceedings.
- The Court found special or compelling reasons to construe the complaint as an unlawful detainer action and to uphold the MeTC’s jurisdiction despite imprecise pleading by counsel for respondent and the mixed allegations.
Merits: Possession and Right to Eject
- The Court analyzed possession de facto: petitioner’s possession began as legal (as tenant)
Case Syllabus (G.R. No. 203160)
Citation and Panel
- Reported at 539 Phil. 158, Third Division, G.R. No. 139442, December 06, 2006.
- Decision penned by Justice Velasco, Jr.
- Concurrence by Justices Quisumbing (Chairperson), Carpio, Carpio-Morales, and Tinga.
The Case (Nature and Relief Sought)
- Petition for review on certiorari seeking nullification of the Court of Appeals’ April 30, 1999 Decision and July 16, 1999 Resolution in CA‑G.R. SP No. 49097.
- Relief sought: annulment of CA rulings that reversed the Manila RTC decision in Civil Case No. 98‑89174 and reinstated the Manila MeTC Decision ordering petitioner Lourdes Dela Cruz to vacate the subject lot in favor of respondent Melba Tan Te.
Relevant Chronology (Key Dates and Procedural Milestones)
- Late 1989: Fire destroyed petitioner’s dwelling on the subject lot.
- February 21, 1994: Written demand served on petitioner to vacate the lot.
- November 26, 1996: Reyeses sold the lot to respondent Melba Tan Te via Deed of Absolute Sale.
- January 14, 1997: Written demand by respondent to relinquish premises.
- September 8, 1997: Ejectment complaint filed by Tan Te in Manila MeTC (Civil Case No. 156730‑CV).
- October 24, 1997: Petitioner filed answer raising jurisdictional and substantive defenses.
- April 3, 1998: Manila MeTC rendered judgment for plaintiff (Tan Te).
- September 1, 1998: Manila RTC set aside MeTC decision and dismissed Tan Te’s complaint (Civil Case No. 98‑89174).
- September 25, 1998: Tan Te filed appeal with the Court of Appeals (CA‑G.R. SP No. 49097).
- April 30, 1999: Court of Appeals reversed RTC and reinstated MeTC decision.
- July 16, 1999: Court of Appeals denied petitioner’s motion for reconsideration.
- December 06, 2006: Supreme Court decision in G.R. No. 139442.
Undisputed Facts (Parties, Property, and Possession)
- The Reyes family, represented by Lino Reyes, owned the lot at No. 1332 Lacson Street (formerly Gov. Forbes Street), Sampaloc, Manila.
- Petitioner Lourdes Dela Cruz was a lessee who had paid rent over a portion of the lot for well over 40 years.
- A fire circa 1989 destroyed petitioner’s dwelling; petitioner and some tenants returned and rebuilt houses thereafter.
- The Reyes family made repeated verbal demands for lessees, including petitioner, to vacate; petitioner did not comply.
- Petitioner was served a written demand on February 21, 1994, and again after sale to Tan Te on January 14, 1997.
- The lot was sold by the Reyeses to respondent Melba Tan Te by Deed of Absolute Sale dated November 26, 1996; respondent purchased for residential purposes.
- Despite sale and demands, petitioner refused to vacate, prompting barangay conciliation, a certificate to file action, and ultimately an ejectment complaint.
Allegations in Tan Te’s MeTC Complaint (Verbatim Elements Quoted in Record)
- Plaintiff is the absolute and registered owner of the parcel at No. 1332 Lacson Street, now occupied by defendant.
- Plaintiff purchased the parcel on November 26, 1996, by Deed of Absolute Sale; title transferred as evidenced by TCT No. 233273 issued April 22, 1997.
- Prior to sale, previous owners (represented by Lino Reyes) were in possession and control of the property.
- Prior to sale, defendant (petitioner) surreptitiously and by means of stealth and strategy entered, used and occupied the premises thereby depriving the former of rightful possession.
- On February 21, 1994, Lino Reyes through counsel furnished defendants a letter formally demanding defendant vacate the premises; defendant failed and refused.
- After the sale, plaintiff made several demands to vacate, the last on January 14, 1997; defendant failed and refused to vacate without legal cause.
Petitioner’s Answer (Primary Defenses and Assertions)
- The MeTC lacked jurisdiction because the forcible entry action was filed beyond the one‑year period reckoned from the date of alleged unlawful entry.
- Petitioner alleged she was a rent‑paying tenant protected by PD 20 and related rental control laws (including B.P. Blg. 25), with a long‑standing tenancy dating to the Dimayuga family; lease had no definite duration and rent rose from P60.00 monthly to P300.00 by November 1996.
- Petitioner asserted rights of a bona fide tenant: protection from ouster except for causes prescribed by law, right of first refusal under P.D. 1571 on sale, and that her lease constituted a legal encumbrance binding successors‑in‑interest.
- Petitioner stated she filed a petition for consignation of rent before the MeTC and alleged the land was subject of expropriation proceedings.
- Petitioner raised procedural contention that a married woman plaintiff must be joined by her husband.
Manila MeTC Ruling (April 3, 1998)
- Judgment in favor of plaintiff (Tan Te) ordering defendant and persons claiming under her to vacate premises at 1332 Lacson Street and peacefully return possession to plaintiff.
- Ordered defendant to pay plaintiff P360.00 per month from December 1996 to November 1997; P432.00 per month from December 1997 to November 1998, plus 20% for each subsequent year until premises vacated and turned over.
- Ordered defendant to pay plaintiff P10,000.00 as attorney’s fees, and awarded costs of suit.
Manila RTC Ruling (September 1, 1998)
- RTC set aside the MeTC Decision and dismissed Tan Te’s complaint on ground that regional trial court, not MeTC, had jurisdiction.
- RTC reasoning: Tan Te’s predecessor (the Reyeses) learned of petitioner’s intrusion on February 21, 1994; the ejectment suit should have been filed within the one‑year prescriptive period expiring on February 21, 1995.
- Because no ejectment suit was filed by the Reyeses within that year and Tan Te filed only on September 8, 1997, the action had become an accion publiciana cognizable by the RTC.
Court of Appeals Ruling (April 30, 1999) and Resolution (July 16, 1999)
- CA reversed the Manila RTC September 1, 1998 Decision and reinstated the Manila MeTC April 3, 1998 Decision ordering ejectment.
- CA denied petitioner’s motion for reconsideration on July 16, 1999.
- Petitioner’s recourse to the Supreme Court followed.
Issues Raised on Petition for Review
- Petitioner alleges two reversible errors by the Court