GR 158231; (June, 2007) (Digest)
G.R. No. 158231 , June 19, 2007
Baby Arlene Laraño, Petitioner, vs. Sps. Alfredo Calendacion and Rafaela T. Calendacion, Respondents.
FACTS
Petitioner Baby Arlene Laraño and respondent spouses executed a Contract to Sell covering a portion of petitioner’s riceland. Respondents paid a down payment, with the balance payable in installments until September 2001. Pending full payment, possession was transferred to respondents under the obligation to account for and deliver the harvests to petitioner. Respondents defaulted on their installment payments and failed to deliver the harvests. Petitioner sent a demand letter to vacate and, upon respondents’ failure to comply, filed a complaint for unlawful detainer before the Municipal Trial Court (MTC).
The MTC ruled in favor of petitioner, ordering respondents to vacate and pay compensation. The Regional Trial Court (RTC) affirmed the MTC decision on appeal, with a modification on the compensation amount. Respondents then filed a Petition for Review with the Court of Appeals (CA).
ISSUE
Whether the Court of Appeals erred in dismissing the unlawful detainer complaint on the ground that the MTC lacked jurisdiction, holding that the case involved issues beyond mere possession and was thus incapable of pecuniary estimation.
RULING
The Supreme Court reversed the CA and reinstated the RTC decision. The Court held that the MTC correctly exercised jurisdiction over the unlawful detainer case. Jurisdiction is determined by the allegations in the complaint. Petitioner’s complaint expressly alleged a cause of action for unlawful detainer based on the expiration of respondents’ right to possess the land under the Contract to Sell due to their violation of its terms—specifically, their failure to pay installments and account for harvests. The case was therefore one for ejectment, where the issue of possession is paramount and can be resolved independently of any claim for specific performance or resolution of the contract. The MTC is vested with jurisdiction over such ejectment cases. The CA erred in characterizing the suit as one incapable of pecuniary estimation, which would fall under RTC jurisdiction, by delving into matters beyond the possessory issue presented in the complaint. The verification defect in the CA petition was correctly deemed a formal, waivable defect, not a jurisdictional flaw.