G.R. No. 83581 June 14, 1989
PHILIPPINE FEEDS MILLING CO., INC., petitioner, vs. HON. COURT OF APPEALS & HON. EDILBERTO G. SANDOVAL, as Judge of the Regional Trial Court of Manila, Br. 9, and UY BUN TIONG, respondents.

FACTS

Sy Tian Peng owned a commercial building leased to several tenants, including petitioner Philippine Feeds Milling Co., Inc. and private respondent Uy Bun Tiong. In June 1982, Sy Tian Peng offered the tenants an option to purchase the property. Only petitioner formally signified its intent to buy. After negotiations, petitioner and Sy Tian Peng agreed on a sale price of P800,000 in May 1983. Petitioner paid the full price and received a deed of sale on June 30, 1983, with the transfer registered on July 22, 1983. As the new owner, petitioner informed Uy Bun Tiong in October 1983 that it needed the premises for its own use and later sent a notice to vacate in April 1984. Uy Bun Tiong, however, had stopped paying rent in March 1984 and, with other tenants, filed an action for specific performance against the former and new owners, claiming a right to purchase the property. Petitioner subsequently filed an ejectment case for non-payment of rent and unauthorized sublease.

ISSUE

Whether the Metropolitan Trial Court had jurisdiction over the ejectment case filed by petitioner against respondent, notwithstanding the respondent’s claim of an alleged right to purchase the property which was raised in a separate pending action.

RULING

Yes, the Metropolitan Trial Court retained jurisdiction. The Supreme Court held that jurisdiction in ejectment cases is determined by the allegations in the complaint, which in this case sufficiently averred petitioner’s ownership and a cause of action for unlawful detainer based on non-payment of rent and the owner’s need for the premises. The respondent’s defense, which involved a claim of a right to purchase the property, did not divest the inferior court of its jurisdiction. The Court emphasized that a lessee is estopped from denying the title of his landlord, and Uy Bun Tiong’s act of paying rent to the petitioner for several months constituted recognition of petitioner’s ownership. The pending action for specific performance involving the question of title could not pre-empt the summary ejectment proceeding, as the issue of possession could be resolved independently. Furthermore, the lease being on a month-to-month basis for a commercial property, the new owner had the right to terminate it. The decisions of the Regional Trial Court and Court of Appeals dismissing the ejectment case for lack of jurisdiction were reversed, and the Metropolitan Trial Court’s judgment in favor of the petitioner was reinstated.