G.R. No. L-49059. May 29, 1980.
NUEVA VIZCAYA CHAMBER OF COMMERCE, RAMON UY, TAN LIONG CHIONG, EDWARD CHAN and CUA HIAN SIU, petitioners, vs. COURT OF APPEALS, HON. VICENTE R. CAMPOS, Presiding Judge, Court of First Instance of Nueva Vizcaya, Branch III, and PEDRO BUSA, respondents.

FACTS

Respondent Pedro Busa filed an ejectment complaint on January 13, 1975, in the Municipal Court of Solano against petitioners, who were occupying his lot. The complaint alleged that petitioners occupied the land without a lease contract and without paying compensation. The municipal court dismissed the complaint. Busa appealed to the Court of First Instance (CFI), which found that petitioners originally occupied the lot under a 15-year lease contract expiring on April 15, 1972. After the lease expired, Busa sent demand letters, including one dated July 22, 1974, informing petitioners he would not renew the lease and requiring them to vacate and pay reasonable compensation. The CFI ruled in favor of Busa, ordering petitioners to vacate and pay monthly compensation from April 17, 1972.
Petitioners sought review in the Court of Appeals, which dismissed their petition. Their motion for reconsideration was denied, and the CFI decision became final. Petitioners then filed this certiorari action with the Supreme Court, challenging jurisdiction.

ISSUE

Whether the municipal court had jurisdiction over the ejectment case, considering petitioners’ defense that the lease contract contained a renewal clause at their option, thereby allegedly transforming the action into one incapable of pecuniary estimation.

RULING

The Supreme Court dismissed the petition, upholding the municipal court’s jurisdiction. The Court ruled that jurisdiction in ejectment cases is determined by the allegations in the complaint. Busa’s complaint was for unlawful detainer, based on the expiration of the lease and subsequent demands to vacate, the last being within one year before filing the suit, which is compliant with jurisdictional requirements.
The Court clarified that even if the case involved interpreting the renewal clause, jurisdiction remained with the municipal court because the basis for ejectment was nonpayment of rentals after the lease term ended, not the resolution of the renewal option itself. The CFI found petitioners liable for nonpayment “whether from April 17, 1972 or after October, 1973,” which is a matter within the inferior court’s competence. The ruling in Vda. de Murga vs. Chan, where interpretation of a renewal clause placed the case beyond municipal court jurisdiction, was deemed inapplicable here.
Furthermore, the Court noted that petitioners raised the jurisdictional issue based on the nature of the action being incapable of pecuniary estimation only in their motion for reconsideration in the Court of Appeals, not in the lower courts. While jurisdiction over subject matter cannot generally be waived, there is basis for respondent’s contention that petitioners may be estopped from belatedly challenging it after submitting to the CFI’s original jurisdiction without objection. The CFI decision was declared final and enforceable.