GR 124148; (May, 2004) (Digest)
G.R. No. 124148; May 20, 2004
PACITA G. VARONA, ORLANDO AYSON, MILA CASTILLO-SI and ANGELITA P. SABINO, petitioners, vs. COURT OF APPEALS and EVANGELINE LIM, respondents.
FACTS
Petitioners were issued Mayor’s Permits on February 16, 1994, authorizing their occupancy of specific stalls in the New Pampang Public Market in Angeles City. Relying on these permits, they filed ejectment complaints against private respondent Evangeline Lim, the current occupant, before the Municipal Trial Court (MTC) in March 1994. However, on March 22, 1994, the City Mayor revoked the petitioners’ permits on the grounds that their names were not on the official Master List of Stallholders and they failed to secure the required clearance from the Market Administrator prior to the permits’ issuance.
The MTC ruled in favor of the petitioners and ordered Lim’s ejectment. On appeal, the Regional Trial Court (RTC) reversed the MTC, declaring that Lim had a better right to possession and that the ejectment cases had become moot and academic due to the revocation of the permits, which was a supervening event. The Court of Appeals affirmed the RTC’s decision in full.
ISSUE
Whether the MTC had jurisdiction over the ejectment complaints filed by the petitioners.
RULING
The Supreme Court granted the petition but modified the appellate court’s decision. It held that the MTC lacked jurisdiction over the complaints, which were improperly filed as actions for forcible entry or unlawful detainer. For forcible entry, the plaintiff must allege prior physical possession and that they were deprived thereof by force, intimidation, threat, strategy, or stealth. For unlawful detainer, the possession must have been initially lawful, by virtue of a contract, and was later unlawfully withheld after the expiration or termination of the right to hold possession.
The complaints failed to meet these jurisdictional requirements. They were based solely on the Mayor’s Permits and did not allege that Lim’s entry was by force or stealth, nor did they establish any contractual relationship between the parties that would give rise to a detainer scenario. The revocation of the permits prior to the filing of some complaints and during the pendency of others did not merely render the cases moot; it highlighted the absence of a valid cause of action for ejectment from the outset. Consequently, the MTC had no jurisdiction. The RTC, therefore, erred in ruling on the merits of possession. Its decision should have been limited to reversing the MTC for lack of jurisdiction, without making a determination on who had a better right of possession. The Supreme Court modified the decision accordingly.