G.R. No. 172217 ; September 18, 2009
SPOUSES LYDIA FLORES-CRUZ and REYNALDO I. CRUZ, Petitioners, vs. SPOUSES LEONARDO and ILUMINADA GOLI-CRUZ, et al., Respondents.

FACTS

Petitioners purchased a parcel of land in Bulacan in December 1999. Upon inspection, they discovered respondents occupying portions of the property. Petitioners claimed respondents were allowed to stay by the deceased former owner, Estanislao Flores, petitioners’ predecessor. After failed negotiations to sell the occupied portions, petitioners, through counsel, sent formal demand letters to vacate on March 2, 2001. Respondents refused, asserting possession ranging from 10 to 20 years and claiming the land was alienable public land. Petitioners filed a complaint for recovery of possession in the Regional Trial Court (RTC) on August 6, 2001.
The RTC ruled in favor of petitioners. On appeal, the Court of Appeals reversed, holding that the RTC lacked jurisdiction. The CA characterized the action as one for unlawful detainer, not an accion publiciana, because the complaint’s allegations indicated petitioners’ tolerance of respondents’ possession and the suit was filed within one year from the demand to vacate. Consequently, jurisdiction properly pertained to the Municipal Trial Court. Petitioners sought review by the Supreme Court.

ISSUE

Whether the Regional Trial Court had jurisdiction over the complaint filed by the petitioners.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. Jurisdiction is determined by the allegations in the complaint at the time of its filing. Petitioners’ complaint alleged that respondents’ possession originated from the permission of the former owner, Estanislao Flores, and that petitioners, as successors, merely tolerated such occupancy until they sent the demand to vacate. These allegations squarely constitute a case for unlawful detainer under Section 1, Rule 70 of the Rules of Court, as it is based on the termination of the possessor’s right by a demand to vacate.
An unlawful detainer action must be filed within one year from the date of last demand. Petitioners’ demand was made on March 2, 2001, and the complaint was filed on August 6, 2001, well within the one-year period. Therefore, the case fell under the exclusive original jurisdiction of the Municipal Trial Court, not the Regional Trial Court. The RTC’s decision was correctly declared null and void for lack of jurisdiction. The nature of the action cannot be altered by evidence presented during trial; it is fixed by the complaint’s material allegations.