Case Summary (G.R. No. 195477)
Petitioner
Spouses Herminio E. Erorita and Editha C. Erorita
Respondent
Spouses Ligaya Dumlao and Antonio Dumlao; Hernan and Susan Erorita (appointed administrators of the Academy)
Key Dates
• April 25, 1990 – Dumlaos purchase property at foreclosure sale.
• December 16, 2002 – Dumlaos demand that petitioners vacate.
• March 4, 2004 – Complaint for recovery of possession filed in RTC.
• June 4, 2007 – RTC rules in favor of Dumlaos, ordering vacation, rents, damages.
• July 28, 2010 – Court of Appeals (CA) affirms RTC.
• January 4, 2011 – CA denies petitioners’ motion for reconsideration.
• January 25, 2016 – Supreme Court issues decision on certiorari.
Applicable Law
– 1987 Philippine Constitution (post-1990 jurisprudence)
– Republic Act No. 7691 (expanding jurisdiction of trial courts) in relation to Batas Pambansa Blg. 129
– Rules on actions for unlawful detainer vs. accion publiciana
– Doctrine on subject-matter jurisdiction and estoppel by laches
Factual Background
After failing to redeem the foreclosed property, the Eroritas continued operating San Mariano Academy under an alleged verbal agreement to pay ₱20,000/month. No rentals were paid. Dumlaos initially consented to continued operation but later demanded vacation. Petitioners could not immediately close the school due to DepEd clearance requirements.
Procedural History
Dumlaos filed for recovery of possession in the RTC. The Eroritas defaulted at pre-trial. The RTC, treating the complaint as an accion publiciana, ordered turnover, rent arrears, damages, attorneys’ fees, and enjoined new enrollment. The CA affirmed jurisdiction and merits, holding the assessed value exceeded MTC thresholds. Petitioners sought certiorari relief before the Supreme Court.
Issue I – Jurisdiction of RTC vs. MTC
The nature of the complaint’s allegations controls jurisdiction. A valid unlawful detainer action requires (1) lawful initial possession, (2) demand to vacate, (3) refusal, and (4) filing within one year of demand. Here the complaint pleaded each element and was filed within one year of the February 12, 2004 demand. Under RA 7691, unlawful detainer falls exclusively within MTC jurisdiction regardless of assessed value. The RTC thus acted without jurisdiction, rendering its decision void and warranting reversal of the CA’s affirmance.
Issue II – Improper Impleader
Hernan and Susan Erorita were prima facie real parties in interest as administrators benefiting from the lease. However, the petitioners did not raise this issue in the RTC or CA. Under settled rules, issues not advanced in the lower courts are deemed waived and may not
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Antecedents
- Spouses Ligaya and Antonio Dumlao are registered owners of a parcel of land in Barangay San Mariano, Roxas, Oriental Mindoro, covered by TCT No. T-53000, on which the San Mariano Academy stands.
- The Dumlaos acquired the property by extrajudicial foreclosure sale on April 25, 1990, consolidated title due to Spouses Herminio and Editha Erorita’s failure to redeem.
- The Dumlaos allowed the Eroritas to continue operating the school; the Dumlaos alleged an agreement for a monthly rent of ₱20,000.00 which remained unpaid, while the Eroritas claimed free use out of goodwill.
- On December 16, 2002, the Dumlaos demanded that the Eroritas vacate; the latter delayed closing pending Department of Education clearance.
- On March 4, 2004, the Dumlaos filed a complaint for recovery of possession (Civil Case No. C-492) before the RTC against Hernan and Susan Erorita and Spouses Erorita.
- The defendants answered, prayed for dismissal, and contested their obligation to vacate or pay rentals.
- Defendants failed to appear at pre-trial, were declared in default, and RTC conducted ex parte proceedings.
- On June 4, 2007, the RTC ordered immediate vacation and turnover of the property, payment of rentals, damages, attorney’s fees, and prohibited further enrollments.
Court of Appeals Ruling
- The CA affirmed the RTC decision, holding that under Republic Act No. 7691 the assessed value of the property and improvements exceeded ₱20,000.00, thus vesting jurisdiction in the RTC.
- The CA treated the action as one for