G.R. No. 191527 , August 22, 2016
BALIBAGO FAITH BAPTIST CHURCH, INC. AND PHILIPPINE BAPTIST S.B.C., INC., PETITIONERS, VS. FAITH IN CHRIST JESUS BAPTIST CHURCH, INC. AND REYNALDO GALVAN, RESPONDENTS.

FACTS

Petitioners Balibago Faith Baptist Church, Inc. (BFBC) and Philippine Baptist S.B.C., Inc. (PBSBC) filed a Complaint for unlawful detainer and damages against respondents Faith in Christ Jesus Baptist Church, Inc. (FCJBC) and Reynaldo Galvan before the Municipal Trial Court (MTC) of Angeles City. PBSBC is the registered owner of the subject property. On March 7, 1990, PBSBC granted a loan to BFBC to purchase the property, and BFBC took possession and held religious activities there. Respondent Galvan and his companions later joined BFBC’s services. Petitioners alleged that Galvan formed FCJBC and took control of the property. After a demand to vacate was ignored, petitioners filed the ejectment case. Respondents claimed they were the original occupants, having originated from Faith Baptist Church (FBC), which obtained the loan, and that they had attempted to pay but PBSBC refused acceptance. They also filed a separate Petition for Consignation. The MTC ruled in favor of petitioners, characterizing the case as one of forcible entry, and ordered respondents to vacate. The Regional Trial Court (RTC) affirmed the MTC Decision. The Court of Appeals (CA) reversed, dismissed the complaint, and held that the MTC had no jurisdiction.

ISSUE

Whether the instant case is one of unlawful detainer or forcible entry, which determines the jurisdiction of the MTC.

RULING

The Supreme Court DENIED the petition and AFFIRMED the CA Decision. The case is not one of unlawful detainer but potentially of forcible entry, and the MTC lacked jurisdiction because the allegations in the complaint were insufficient to establish a cause of action for either.
1. Distinction between Forcible Entry and Unlawful Detainer: Forcible entry involves deprivation of possession through force, intimidation, threat, strategy, or stealth; possession is illegal from the beginning. Unlawful detainer involves the lawful withholding of possession becoming illegal after the expiration or termination of the right to possess.
2. Allegations in the Complaint are Controlling: The cause of action is determined by the facts alleged in the body of the complaint, not its designation. To sufficiently allege unlawful detainer, the complaint must state: (a) defendant’s initial possession was by contract with or tolerance of the plaintiff; (b) such possession became illegal upon plaintiff’s notice of termination; (c) defendant remained in possession; and (d) the action was filed within one year from the last demand to vacate.
3. Petitioners’ Complaint was Deficient: The complaint alleged that respondents “joined” petitioners’ services and then “took possession and control” of the property. These allegations suggest entry was illegal from the start, which is characteristic of forcible entry, not unlawful detainer. The complaint failed to allege that respondents’ initial possession was lawful or by petitioners’ tolerance, a requisite for unlawful detainer.
4. Jurisdictional Consequences: Since the allegations did not properly set forth a case of unlawful detainer, and a forcible entry case must be filed within one year from the date of actual entry (or from discovery if by stealth), the MTC had no jurisdiction. The proper recourse for petitioners would have been a plenary action for recovery of possession in the RTC.
5. Jurisdiction May Be Raised at Any Time: Lack of jurisdiction can be raised at any stage, as it affects the court’s very authority to render judgment. A void judgment creates no rights or obligations.
Thus, the complaint was correctly dismissed for lack of jurisdiction.