GR 202217; (April, 2018) (Digest)
G.R. No. 202217 APRIL 25, 2018
PABLO C. HIDALGO, Petitioner vs. SONIA VELASCO, Respondent
FACTS
Petitioner Pablo Hidalgo filed a Complaint for Unlawful Detainer with Damages before the Municipal Circuit Trial Court (MCTC) against respondent Sonia Velasco. Hidalgo claimed ownership over a residential lot by virtue of a Deed of Donation executed in 2000. He alleged that he discovered Velasco in possession of the property during a visit in January 2005. He subsequently sent demand letters, with the last one dated January 9, 2006, asking her to vacate. Velasco refused, asserting her possession was derived from a certain Josefina Reintegrado Baron, whom she claimed was the owner. Hidalgo filed his ejectment complaint on December 8, 2006.
The MCTC dismissed the complaint for lack of jurisdiction, a ruling affirmed by the Regional Trial Court (RTC) and the Court of Appeals (CA). The courts held that the allegations in the complaint failed to establish a case for unlawful detainer, which falls under the MCTC’s exclusive original jurisdiction. Hidalgo elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the Court of Appeals erred in affirming the dismissal of the complaint for unlawful detainer on the ground of lack of jurisdiction.
RULING
The Supreme Court denied the petition and affirmed the CA’s ruling. The Court emphasized that jurisdiction over ejectment cases is determined by the allegations in the complaint. For unlawful detainer, the plaintiff must allege that the possession was initially lawful, beginning with the defendant’s tolerance or contract with the owner, and that such possession became unlawful upon the owner’s demand to vacate which was refused. The complaint must specifically state when and how the defendant entered the property.
The Court found Hidalgo’s complaint fatally deficient. It merely stated he “was surprised to know” Velasco was occupying the lot in January 2005 and that he later sent demand letters. It did not allege how Velasco’s possession began—whether by force, intimidation, threat, strategy, stealth, or, crucially for unlawful detainer, by Hidalgo’s tolerance or a lease agreement. Without these essential jurisdictional facts, the complaint did not make out a case for unlawful detainer. The one-year filing period for such an action, counted from the date of last demand, therefore did not apply. The proper remedy for Hidalgo, involving a plenary action to recover possession, falls within the jurisdiction of the RTC, not the MCTC. The dismissal for lack of jurisdiction was thus correct.