G.R. No. 172447 & G.R. No. 179404; September 18, 2009
Iglesia Evangelica Metodista en las Islas Filipinas (IEMELIF), Inc. vs. Natanael B. Juane (Consolidated Cases)

FACTS

IEMELIF, a religious corporation, filed an unlawful detainer complaint against its former pastor, Rev. Natanael Juane, before the Metropolitan Trial Court (MeTC) of Manila. IEMELIF alleged it is the registered owner of the cathedral complex in Tondo, Manila, which includes a pastor’s residence. Juane was appointed as Resident Pastor of the Cathedral in 2000 and 2001, authorizing his occupancy. In March 2002, he was reassigned to another congregation, terminating his authority to occupy the premises. In May 2002, he was expelled as a pastor by the church’s Highest Consistory of Elders. Despite a formal demand to vacate, Juane refused to leave the cathedral premises, compelling IEMELIF to rent another space for worship.
Juane moved to dismiss the complaint, arguing the MeTC had no jurisdiction. He contended the case involved an intra-corporate dispute over his removal as pastor, falling under the jurisdiction of the Securities and Exchange Commission (SEC), or later the Regional Trial Court (RTC) acting as a commercial court. The MeTC denied his motion, a decision affirmed by the RTC. The Court of Appeals initially granted Juane’s petition in G.R. No. 172447, dismissing the case for lack of jurisdiction. However, in the main case for unlawful detainer (G.R. No. 179404), the Court of Appeals later affirmed the MeTC’s and RTC’s findings that Juane was guilty of unlawful detainer.

ISSUE

The core issue is whether the MeTC had jurisdiction over the complaint for unlawful detainer, or whether the case was an intra-corporate dispute beyond its jurisdiction.

RULING

The Supreme Court ruled that the MeTC properly exercised jurisdiction over the unlawful detainer case. The Court clarified the nature of an ejectment suit, emphasizing that its primary objective is to resolve the issue of physical possession (possession de facto) independently of claims of ownership. Jurisdiction is conferred by the allegations in the complaint regarding the nature of the action and the relief sought.
IEMELIF’s complaint sufficiently alleged a cause of action for unlawful detainer under Rule 70 of the Rules of Court. It stated that Juane’s possession was initially lawful by virtue of his appointment but became unlawful upon the termination of his authority through reassignment and subsequent expulsion, and his refusal to vacate after a valid demand. The complaint focused on the deprivation of physical possession, not the validity of his removal as a pastor or corporate officer. The Court held that the case was fundamentally a simple action to recover possession of property, not an intra-corporate controversy. The existence of a landlord-tenant relationship is not required in unlawful detainer; it is enough that possession was initially lawful but later became unlawful by the expiration of one’s right. Consequently, the Court reversed the Court of Appeals’ decision in G.R. No. 172447 (granting the motion to dismiss) and affirmed its decision in G.R. No. 179404 (finding unlawful detainer).