GEORGIA T. ESTEL, Petitioner, vs. RECAREDO P. DIEGO, SR. and RECAREDO R. DIEGO, JR., Respondents.
FACTS
The case originated from a Complaint for Forcible Entry, Damages and Injunction filed by respondents Recaredo P. Diego, Sr. and Recaredo R. Diego, Jr. with the Municipal Trial Court in Cities (MTCC) of Gingoog City. Respondents alleged that on April 16, 1991, they entered into a contract of sale for a 306-square-meter parcel of land (Lot 19) with petitioner Georgia T. Estel. After receiving a downpayment of ₱17,000.00, petitioner voluntarily delivered physical possession of the property to respondents, who had been in actual, adverse, and uninterrupted possession since then. On July 20, 1995, petitioner, together with her sons and others, allegedly uprooted the fence, entered the premises, and destroyed trees and plants on the lot. Respondents sought restoration of possession, a permanent injunction, and damages.
In her Answer, petitioner denied respondents’ possession, claimed full possession and ownership remained with her and her daughter, stated the sale agreement had been abrogated, and offered to return the downpayment. She contended that the subject of the deed of sale and what was delivered was actually the adjacent Lot 16, not Lot 19, and that any improvements were planted by her parents.
The MTCC ruled in favor of respondents, ordering petitioner to vacate, pay rentals, actual damages for the destroyed fence and plants, attorney’s fees, and litigation costs. The Regional Trial Court (RTC) affirmed the MTCC Decision on appeal. The Court of Appeals (CA) subsequently affirmed the RTC Decision and denied petitioner’s Motion for Reconsideration.
Petitioner elevated the case to the Supreme Court, arguing that: (1) the MTCC lacked jurisdiction over the subject matter because respondents’ complaint failed to allege the location of the disputed land and facts constitutive of forcible entry; (2) the complaint stated no cause of action due to defective verification and certificate of non-forum shopping; and (3) the findings of fact by the lower courts were unsupported by evidence.
ISSUE
1. Whether the MTCC acquired jurisdiction over the subject matter of the forcible entry case.
2. Whether the complaint stated a cause of action.
3. Whether the factual findings of the lower courts were supported by evidence.
RULING
The Supreme Court DENIED the petition and AFFIRMED the assailed CA Decision and Resolution.
1. On Jurisdiction: The Court held that the MTCC properly acquired jurisdiction. Petitioner failed to raise the issue of jurisdiction or the alleged lack of geographical location in the complaint in her Answer before the MTCC or in her appeal to the RTC. By actively participating in all stages of the proceedings, petitioner was estopped from belatedly challenging jurisdiction. The Court emphasized that estoppel sets in when a party submits to a court’s jurisdiction and only attacks it after an adverse decision. Furthermore, the action was clearly one for forcible entry, which falls under the exclusive original jurisdiction of first-level courts (MTCC, MTC, MCTC) pursuant to Section 33 of B.P. Blg. 129, as amended, and Section 1, Rule 70 of the Rules of Court. The omission of the property’s location in the complaint, given that evidence showed it was in Gingoog City and petitioner did not object, was a mere matter of venue and a pure technicality. The Court also found that respondents sufficiently alleged the mandatory elements for forcible entry: prior physical possession by the plaintiff and deprivation of that possession through force, intimidation, threat, strategy, or stealth.
2. On Cause of Action: The Court rejected petitioner’s claim that the complaint stated no cause of action due to defective verification and certificate of non-forum shopping. The defects alleged were not jurisdictional and did not render the complaint an unsigned pleading. The verification, based on “knowledge, information and belief,” was acceptable. The alleged incompleteness of the certificate of non-forum shopping (specifically, the lack of an undertaking to report a similar pending action) was a formal, not a jurisdictional, defect. The Court reiterated that the rule on the certificate of non-forum shopping should not be interpreted with absolute literalness that subverts its intent.
3. On Factual Findings: The Court upheld the factual findings of the lower courts. In a petition for review on certiorari under Rule 45, the Court’s jurisdiction is limited to reviewing errors of law, not re-examining factual findings. The factual conclusions of the trial courts, especially when affirmed by the CA, are generally binding and conclusive upon the Supreme Court, provided they are supported by the evidence on record. The Court found no compelling reason to deviate from this rule, as the lower courts’ findings were supported by competent evidence.
*The Court found no merit in petitioner’s arguments and affirmed the lower courts’ decisions in their entirety.*
