GR 196795; (March, 2018) (Digest)
G.R. No. 196795 , March 7, 2018
Intramuros Administration vs. Offshore Construction Development Company
FACTS
Petitioner Intramuros Administration (IA) leased government properties to respondent Offshore Construction Development Company (OCDC) under contracts from 1998 to 2003, with a provision for renewal by mutual agreement. Disputes arose, leading to a 1999 Compromise Agreement approved by the RTC, which affirmed but modified the lease terms. OCDC subsequently failed to pay rental and utility arrears. Despite a subsequent Memorandum of Agreement to settle debts, OCDC continued in default. IA sent a final demand letter and then filed an ejectment complaint before the Metropolitan Trial Court (MeTC).
In its defense, OCDC filed a motion to dismiss, arguing the MeTC lacked jurisdiction because the parties’ relationship was governed by a concession agreement, not a simple lease. OCDC also alleged IA committed forum shopping due to two other pending RTC cases involving the same parties and properties. The MeTC granted the motion and dismissed the complaint, a decision affirmed by the Regional Trial Court (RTC). IA elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the MeTC correctly dismissed the ejectment complaint for lack of jurisdiction and due to forum shopping.
RULING
The Supreme Court reversed the lower courts’ rulings and reinstated the ejectment complaint. The Court clarified that the sole issue in an ejectment suit is physical possession, or possession de facto, based on a legal right to possess prior to the filing of the complaint. Jurisdiction is conferred by the allegations in the complaint. IA’s complaint sufficiently alleged a lessor-lessee relationship that had been terminated due to OCDC’s failure to pay rent, which is a valid cause for ejectment under the Civil Code. OCDC’s defense—that the agreement was a concession—is a matter of evidence that does not oust the MeTC’s jurisdiction over the summary action for possession. The Court emphasized that the defendant’s claims in the answer or motion to dismiss cannot divest the court of its jurisdiction over the possessory issue.
Regarding forum shopping, the Court found no identity of causes of action. The pending RTC cases involved different reliefs: one was for specific performance concerning the Compromise Agreement, and the other was an interpleader suit filed by a third party. The ejectment case, seeking physical possession based on expired leases and unpaid rent, presented a distinct cause of action. The mere involvement of the same parties and properties does not constitute litis pendentia when the rights asserted and reliefs sought are different. Therefore, IA did not commit forum shopping. The case was remanded to the MeTC for further proceedings.