GR 119900; (August, 2001) (Digest)
G.R. No. 119900 ; August 16, 2001
SUNNY MOTORS SALES, INC., petitioner, vs. HONORABLE COURT OF APPEALS, HONORABLE JUDGE OSCAR L. LEVISTE, as the Presiding Judge of the Regional Trial Court, Branch 97, Quezon City, and MS. LOLITA L. SANTIAGO, respondents.
FACTS
Respondent Lolita L. Santiago leased a portion of a property in Quezon City from Ludivina L. Genito for two years, commencing September 9, 1994, for use as a warehouse. She paid a one-year advance rent. On December 16, 1994, petitioner Sunny Motors Sales, Inc., employing guards from a security agency, entered and took possession of the entire property, including the leased portion, barring Santiago from entry. Petitioner claimed it was the new owner, having purchased the property from Genito.
Santiago filed a complaint for damages with a prayer for a temporary restraining order and/or preliminary injunction in the Regional Trial Court (RTC) against Genito and Sunny Motors. Petitioner moved to dismiss the complaint on the ground of lack of jurisdiction, contending the action was actually one for forcible entry, which falls under the exclusive original jurisdiction of the Metropolitan Trial Court (MeTC). The RTC denied the motion to dismiss, a decision affirmed by the Court of Appeals, which held that the complaint, on its face, was a principal action for damages, with injunction merely as an ancillary remedy.
ISSUE
Whether the Regional Trial Court has jurisdiction over the complaint filed by respondent Santiago.
RULING
No. The Supreme Court reversed the decisions of the lower courts and ordered the dismissal of the complaint for lack of jurisdiction. The Court held that jurisdiction over the subject matter is determined by the allegations in the complaint and the character of the relief sought. An examination of the amended complaint revealed that the core allegations constituted a cause of action for forcible entry. Specifically, Santiago alleged that petitioner, “employing guards from the Enriquez Security Agency suddenly entered into possession” of the property, including her leased portion, and barred her from using it. These allegations of being deprived of physical possession through force, intimidation, or strategy are the defining elements of a forcible entry case under Rule 70 of the Rules of Court.
The Court emphasized that the nature of an action cannot be made to depend on the defenses raised by the defendant or the title of the complaint alone. Despite Santiago’s prayer for damages and the label of the complaint, the foundational allegations sought the restoration of her possession, which had been forcibly disrupted. Since an action for forcible entry is within the exclusive original jurisdiction of the MeTC, the RTC had no jurisdiction to take cognizance of the case. Therefore, the RTC should have granted the motion to dismiss.