GR 138258; (January, 2002) (Digest)
G.R. No. 138258; January 18, 2002
EDDIE HERRERA, ERNESTO T. TIJING, and CONRADO BOLLOS, petitioners, vs. TEODORA BOLLOS and RICO GO, respondents.
FACTS
Teodora Bollos filed a complaint for forcible entry before the Municipal Circuit Trial Court (MCTC) against Eddie Herrera. She alleged that in June 1993, Herrera, through stealth and strategy, entered and occupied her sugarland, Lot No. 20, which she inherited from her father. Herrera defended his occupation, claiming he entered Lot No. 21, owned by Conrado Bollos (Teodora’s uncle), as an overseer for lessee Ernesto Tijing. Teodora subsequently amended her complaint twice to implead Tijing and later Conrado Bollos as defendants.
The MCTC dismissed the case for lack of jurisdiction, ruling that Teodora failed to establish a forcible entry case and her proper remedy was a reivindicatory action. On appeal, the Regional Trial Court (RTC) reversed the MCTC. It ordered the defendants’ ejectment from Lot No. 20 and awarded actual damages, moral damages, attorney’s fees, and monthly rentals. The Court of Appeals affirmed the RTC decision but deleted the awards for actual and moral damages.
ISSUE
The core issues were: (1) whether the MCTC retained jurisdiction over the forcible entry case despite the filing of a second amended complaint impleading a new defendant beyond one year from the alleged dispossession; and (2) whether the RTC, on appeal from a dismissal, could properly award damages and order ejectment.
RULING
The Supreme Court denied the petition but set aside the decisions of the CA and RTC, remanding the case to the MCTC for further proceedings. On jurisdiction, the Court held that jurisdiction is determined by the allegations in the complaint at the time of its filing. The original complaint sufficiently alleged a cause of action for forcible entry, detailing prior physical possession by the plaintiff and subsequent deprivation by the defendant through stealth. The nature of the action, as pleaded, vested jurisdiction in the MCTC, and amendments to include other defendants did not divest it of that jurisdiction.
On the propriety of the RTC’s judgment, the Court ruled it was erroneous. In an appeal from a dismissal in an ejectment case, the RTC’s role upon reversal is to remand the case to the inferior court for further proceedings and trial on the merits. It cannot itself directly order ejectment and award damages. The RTC exceeded its appellate authority. Furthermore, damages in forcible entry are limited to accrued rents or the reasonable compensation for use and occupation of the property. Awards for moral, exemplary, or temperate damages are not recoverable in such summary proceedings. The rental value must be proven, and a court cannot take judicial notice of it without evidence and without hearing the parties.