GR 189145; (December, 2013) (Digest)
G.R. No. 189145; December 4, 2013
OPTIMUM DEVELOPMENT BANK, Petitioner, vs. SPOUSES BENIGNO V. JOVELLANOS and LOURDES R. JOVELLANOS, Respondents.
FACTS
Respondents Spouses Jovellanos entered into a Contract to Sell with Palmera Homes, Inc. for a house and lot, making a down payment and taking possession. Palmera Homes later assigned its rights under the contract to petitioner Optimum Development Bank. Due to the spouses’ failure to pay monthly installments, Optimum cancelled the contract and sent a final demand to vacate. Upon their refusal, Optimum filed an unlawful detainer case before the Metropolitan Trial Court (MeTC).
The MeTC ruled in favor of Optimum, ordering the spouses to vacate. The Regional Trial Court (RTC) affirmed this decision on appeal. The Court of Appeals (CA), however, reversed the RTC, dismissing the complaint for lack of jurisdiction. The CA held that the case involved issues beyond mere possession, such as the validity of the contract’s cancellation and rights under Republic Act No. 6552 (the Maceda Law), making it incapable of pecuniary estimation and thus within the exclusive jurisdiction of the RTC.
ISSUE
Whether the MeTC had jurisdiction over the complaint for unlawful detainer.
RULING
Yes, the MeTC had jurisdiction. The Supreme Court reinstated the MeTC and RTC decisions, emphasizing that jurisdiction is determined by the allegations in the complaint and the character of the relief sought. Optimum’s complaint sufficiently alleged a cause of action for unlawful detainer: the spouses’ initial possession was by virtue of the Contract to Sell; such possession became illegal upon cancellation due to non-payment and after demand to vacate; and the complaint was filed within one year from the last demand.
The Court clarified that an unlawful detainer suit focuses solely on the issue of physical possession, independent of any claim of ownership. The defenses raised by the spouses regarding the contract’s validity and the application of RA 6552 did not divest the MeTC of jurisdiction. These matters pertain to the case’s merits, which the MeTC could provisionally resolve only to determine the issue of possession. The primary objective of ejectment proceedings is to prevent breach of peace and criminal disorder by providing a speedy, summary remedy for restoring physical possession. Therefore, the CA erred in dismissing the case for lack of jurisdiction.