GR 147372; (May, 2004) (Digest)
G.R. No. 147372 ; May 27, 2004
CAEZAR Z. LANUZA and ASTERIA LANUZA, petitioners, vs. MA. CONSUELO MUÑOZ, respondent.
FACTS
Respondent Ma. Consuelo Muñoz filed an unlawful detainer complaint against petitioners Caezar and Asteria Lanuza before the MTC of Muntinlupa City. Muñoz claimed ownership of a property acquired from the Lanuzas via a Deed of Absolute Sale in 1996. She alleged that she initially tolerated the Lanuzas’ occupation of two apartment units but withdrew this tolerance in January 1997, demanding they vacate or pay rent. The Lanuzas refused to pay or leave.
The Lanuzas countered that the deed was simulated, signed only to expedite a sale under a profit-sharing agreement with Muñoz’s father, Francisco Muñoz, Sr. They asserted ownership and claimed the subsequent demand for rent was part of a scheme after the agreement allegedly expired. The MTC dismissed the complaint for lack of jurisdiction, finding that a demand to vacate was not properly alleged, a jurisdictional requirement for ejectment. The RTC affirmed this dismissal on appeal.
ISSUE
Whether the Court of Appeals erred in setting aside the RTC decision and remanding the unlawful detainer case to the MTC for further proceedings.
RULING
The Supreme Court affirmed the Court of Appeals’ decision. The appellate court correctly held that the MTC had jurisdiction. The complaint sufficiently alleged a cause of action for unlawful detainer based on the termination of tolerance, not for non-payment of rent. In an action based on the withdrawal of tolerance, the one-year filing period is counted from the date of the last demand to vacate, and the complaint need not detail the specific date of demand with exacting precision to confer jurisdiction; it is enough that it alleges prior tolerance and subsequent withdrawal. The MTC and RTC erred in requiring a specific allegation on the date of demand as a jurisdictional prerequisite in this context.
The Supreme Court emphasized that the core issue for jurisdiction in an ejectment suit is the method by which the defendant entered possession. Here, the complaint alleged possession by tolerance, which falls under the MTC’s jurisdiction. Questions regarding the validity of the sale and ownership, raised by the Lanuzas, are defenses that pertain to the merits of the case and do not affect the MTC’s jurisdiction to hear the ejectment action. These substantive claims must be ventilated in the proper forum, but they do not divest the MTC of its authority to resolve the preliminary issue of possession. Consequently, the remand to the MTC for further proceedings was proper.