G.R. No. 201286 , July 18, 2014
INOCENCIA TAGALOG, Petitioner, vs. MARIA LIM VDA. DE GONZALEZ, GAUDENCIA L. BUAGAS, RANULFO Y. LIM, DON L. CALVO, SUSAN C. SANTIAGO, DINA C. ARANAS, and RUFINA C. RAMIREZ, Respondents.

FACTS

Respondents, co-owners of a parcel of land in Balamban, Cebu, filed a Complaint for Recovery of Possession, Preliminary Mandatory Injunction with Damages against petitioner Inocencia Tagalog. Respondents alleged Tagalog was a lessee on a month-to-month basis under a verbal contract. After Tagalog’s house was damaged by a typhoon and she stopped inhabiting it and paying rent, respondents demanded she vacate, asserting the lease was terminated. Tagalog refused and later began constructing a two-storey house on the land without respondents’ consent. In her Answer, Tagalog claimed the lease was still subsisting and she had permission to repair, and she argued the RTC lacked jurisdiction as the action was for ejectment/unlawful detainer. The RTC ruled in favor of respondents, ordering Tagalog to vacate and pay damages, holding the issue of ownership was primordial. Tagalog’s appeal to the Court of Appeals was dismissed for failure to file the required brief.

ISSUE

Whether the Regional Trial Court had jurisdiction over the subject matter of the action.

RULING

No. The Supreme Court ruled the RTC had no jurisdiction. The nature of the action is determined from the allegations in the complaint. Respondents’ complaint alleged Tagalog’s right to possess under a verbal month-to-month lease had expired, and her subsequent possession was unlawful. The withholding of possession occurred after the expiration of the lease contract, and the complaint was filed within one year from such expiration. This constitutes an action for unlawful detainer, which is within the exclusive original jurisdiction of the Municipal Trial Court, not the RTC. Since the RTC lacked jurisdiction over the subject matter, its proceedings and decision are null and void. The petition was granted.