G.R. No. L-68789 - Lee vs. Presiding Judge, Municipal Trial Court of Legazpi City, Branch I

Case Summary (G.R. No. L-68789)

Procedural and Factual Background

On September 2, 1981, Spouses Roy Po Lam and Josefa Po Lam filed in the then City Court of Legazpi, Branch III, Civil Case No. 2687, an action for ejectment and/or unlawful detainer against Jose Lee. They alleged that the oral contract of lease over their commercial lot and building had expired, and that Jose Lee refused to vacate despite demands. They prayed that the defendant be ordered to vacate and to pay accrued rentals, attorney’s fees, expenses, and exemplary damages.

In his answer filed on September 7, 1981, Jose Lee denied private respondents’ ownership, relying on a final decision of the then Court of Appeals dated March 11, 1981 in CA-G.R. No. 44770, wherein Felix Lim, as intervenor in that earlier case, was declared owner of a portion of the subject property and entitled to exercise the right of redemption over the remaining portion from the subsequent buyer, who was the predecessor-in-interest of the private respondents.

On November 12, 1981, Felix Lim filed an answer in intervention in Civil Case No. 2687, admitted by the trial court. He asserted his status as declared owner of a portion of the property and redemptioner of the rest by virtue of the March 11, 1981 Court of Appeals decision. He specifically questioned the private respondents’ right to receive rentals.

Before the merits in Civil Case No. 2687 began, Felix Lim also filed, on November 3, 1981, a complaint with the then Court of First Instance of Albay docketed as Civil Case No. 6696, contesting the private respondents’ ownership and possession of the same property. He later filed another case on February 9, 1982, Civil Case No. 6767, for reconveyance and annulment of the sale and title involving the property.

After the presiding judge of City Court of Legazpi, Branch III, inhibited himself, Civil Case No. 2687 was transferred to City Court of Legazpi, Branch I, which became the Municipal Trial Court of Legazpi City, Branch I under the reorganized judiciary.

Jose Lee sought to suspend proceedings pending the resolution of Civil Cases Nos. 6696 and 6767. The trial court denied the motion on June 29, 1982. Felix Lim then moved to dismiss Civil Case No. 2687, arguing that the City Court lacked jurisdiction over the nature and subject matter, particularly because the ownership issue belonged to the Court of First Instance. The trial court denied the motion on June 29, 1982. Felix Lim renewed his dismissal motion on August 29, 1982, maintaining that jurisdiction over the ownership issue belonged to the Court of First Instance, while the related cases were pending.

Trial Court Ruling in Civil Case No. 2687

On December 19, 1983, the respondent trial judge rendered decision. The trial court ruled that the Municipal Trial Court of Legazpi City had jurisdiction over the issue of ownership in the ejectment/unlawful detainer case. The decision declared the plaintiffs as lawful owners and entitled to immediate possession of the leased premises, ordered Jose Lee (and anyone acting for him) to vacate and restore possession, directed payment of rentals accruing from October, 1982 up to actual vacation at P2,500.00 a month, subject to deductions for amounts deposited with the City Treasurer’s Office, and awarded exemplary damages and attorney’s fees, plus costs. The intervenor’s claim was denied for lack of merit.

Appeal and Intermediate Appellate Court Disposition

Jose Lee filed a notice of appeal from the December 19, 1983 decision to the Intermediate Appellate Court, and the case was docketed as AC-G.R. CV No. 3397-UDK. On July 9, 1984, the Intermediate Appellate Court dismissed the appeal, holding that it should have been brought to the Regional Trial Court. Jose Lee sought reconsideration on July 12, 1984, but the Intermediate Appellate Court denied the motion in a resolution dated September 5, 1984.

Issues Raised in the Petition

Petitioners assailed (i) the trial court’s decision for allegedly being rendered without jurisdiction or with grave abuse of discretion amounting to lack of jurisdiction when it declared private respondents as lawful owners, and (ii) the Intermediate Appellate Court’s resolutions dismissing the appeal instead of certifying the case to the proper court for determination on the merits.

Petitioners’ Arguments on Jurisdiction of the Trial Court

On the trial court’s jurisdiction, petitioners argued that the Municipal Trial Court had no jurisdiction over the ejectment complaint because the issue of ownership was raised in the pleadings. According to them, when the trial court resolved ownership, it acted without or in excess of jurisdiction, or with grave abuse of discretion amounting to lack of jurisdiction.

They also contended, as to the Intermediate Appellate Court, that the latter acted with grave abuse when it dismissed the appeal rather than certifying the case to the proper court, which would then decide the matter on the merits.

The Court’s Ruling on the Trial Court’s Jurisdiction

The Court rejected petitioners’ challenge to the trial court’s authority to determine ownership as an incident to ejectment/unlawful detainer. It emphasized that when the ejectment complaint was filed on September 2, 1981, the controlling law was R.A. 5967, particularly Section 3, which expressly granted city courts concurrent jurisdiction with the Court of First Instance (now Regional Trial Court) in ejectment cases where the question of ownership is brought in issue in the pleadings, with the issue of ownership to be resolved in conjunction with the issue of possession.

The Court held that because R.A. 5967 governed the commencement of the action, the Municipal Trial Court had jurisdiction and validly rendered the December 19, 1983 decision.

The Court acknowledged that Felix Lim had filed Civil Cases No. 6696 and 6767 in the Court of First Instance, contesting ownership and possession and seeking reconveyance and annulment. However, it ruled that at the time those cases were filed, the City Court had long acquired jurisdiction over Civil Case No. 2687. The Court invoked the established rule that even in concurrent jurisdiction, the court that first acquires jurisdiction excludes the others, and that the authority of a court of competent jurisdiction continues until the matter is finally and completely disposed of, so that no co-ordinate court may interfere. The Court further added that jurisdictional questions were also barred by estoppel because petitioners had actively submitted to the trial court’s jurisdiction: ownership had been joined in the pleadings, petitioners had participated in the trial, examined witnesses, and presented evidence. The Court stated that petitioners could not later adopt an inconsistent stance by attacking jurisdiction after seeking and participating in proceedings before the trial court.

In support, the Court cited the principle articulated in Tijam vs. Sibonghanoy, quoted that a party cannot invoke a court’s jurisdiction to obtain affirmative relief and then repudiate or question that jurisdiction after obtaining or failing to obtain such relief.

Accordingly, the Court held that the trial judge did not render the decision without or in excess of jurisdiction or with grave abuse of discretion amounting to lack of jurisdiction.

The Court’s Ruling on the Intermediate Appellate Court’s Error

On the second issue, the Court held that petitioners’ contention was meritorious. The Court reasoned that the Intermediate Appellate Court should have certified the case to the proper court instead of dismissing the appeal.

The Court explained that under Section 5 of R.A. 5967, decisions of city courts had then been directly appealable to the Court of Appeals. But it held that this arrangement became inoperative when BP 129 took effect on August 14, 1981. Under Section 22 of BP 129, Regional Trial Courts were made to exercise appellate jurisdiction over cases decided by Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts within their territorial jurisdictions. Therefore, Civil Case No. 2687, decided by the city court that became a municipal trial c

Case Syllabus (G.R. No. L-68789)

Parties and Procedural Posture

Petitioners Jose Lee and Felix Lim filed a petition for certiorari and mandamus assailing multiple rulings in a property and possession dispute.
The respondents included the Presiding Judge of the Municipal Trial Court of Legazpi City, Branch I, the Intermediate Appellate Court, and the Spouses Roy Po Lam and Josefa Po Lam.
The petition sought to set aside the Municipal Trial Court decision dated December 19, 1983 in Civil Case No. 2687.
The petition also sought to set aside the Intermediate Appellate Court resolutions dated July 9, 1984 and September 5, 1984 that dismissed the appeal and denied reconsideration.
The alternative prayer requested either the due course of the appeal or certification and remand to the proper court.
The Supreme Court gave due course to the petition and required simultaneous memoranda, which the parties submitted in February 1986 and March 1986.

Key Factual Allegations

The private respondents filed a complaint for ejectment and/or unlawful detainer against Jose Lee on September 2, 1981, docketed as Civil Case No. 2687.
The complaint alleged that an oral contract of lease over a commercial lot and building owned by the private respondents had expired.
The complaint alleged that Jose Lee refused to vacate despite demand.
The private respondents prayed that the court order the defendant to vacate, pay accrued monthly rentals, attorney’s fees, expenses, and exemplary damages.
Jose Lee denied private respondents’ ownership and invoked a final decision of the then Court of Appeals dated March 11, 1981 in CA-G.R. No. 44770, where Felix Lim was declared owner of a portion and entitled to redemption over the remaining portion.
Felix Lim, as intervenor, filed an answer in intervention on November 12, 1981, challenging the private respondents’ right to receive rentals.
The record showed that Felix Lim had filed related suits in the Court of First Instance of Albay, namely Civil Case No. 6696 (questioning ownership and possession) and Civil Case No. 6767 (seeking reconveyance and annulment of sale and title).
Before trial, the case was transferred to Municipal Trial Court of Legazpi City, Branch I after the presiding judge of the City Court Branch where it was originally pending inhibited himself.
Jose Lee moved to suspend proceedings pending final decisions in the Albay cases, but the trial court denied the motion on June 29, 1982.
The intervenor moved to dismiss for alleged lack of jurisdiction, but the trial court likewise denied the motion on June 29, 1982, and later denied subsequent reiteration.

Jurisdictional and Appellate Issues

The first issue asked whether the Municipal Trial Court acted without or in excess of jurisdiction, or with grave abuse of discretion amounting to lack of jurisdiction, when it ruled in the December 19, 1983 decision that private respondents were lawful owners and ordered ejectment.
The second issue asked whether the Intermediate Appellate Court acted with jurisdictional error when it dismissed the appeal instead of certifying the case to the proper court.
Petitioners argued that the trial court lacked jurisdiction because the pleadings raised ownership, which they asserted should have been resolved in the Albay cases.
Petitioners also argued that the intermediate court should have certified the case rather than dismissing the appeal due to the erroneous appellate forum.

Statutory Framework

The trial court’s jurisdiction over ejectment cases was anchored on Section 3 of Republic Act No. 5967, effective June 21, 1969.
Republic Act No. 5967, Section 3 expressly granted city courts concurrent jurisdiction in ejectment cases where ownership is brought in issue in the pleadings, with ownership resolved in conjunction with possession.
The Court emphasized that jurisdiction is determined by the law in force at the time of commencement of the action, citing Laperal vs. Cruz and Rilloraza vs. Arciaga.
On appeal, the Supreme Court treated Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980) as relevant to the proper appellate forum.
B.P. 129, Section 22 provided that Regional Trial Courts exercise appellate jurisdiction over cases decided by Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts in their territorial jurisdictions.
The Supreme Court relied on Rule 50, Section 3 of the Revised Rules of Court, which required that where an appeal was erroneously brought to the Court of Appeals, the appellate court should certify the case to the proper court rather than dismiss it.
The Supreme Court also