GR 93451; (March, 1991) (Digest)
G.R. No. 93451; March 18, 1991
LIM KIEH TONG, INC., petitioner, vs. THE COURT OF APPEALS, HON. JUDGE ROGELIO M. PIZARRO, Presiding Judge of Branch 16 of the Metropolitan Trial Court of Manila, and REGINALDO Y. LIM, respondents.
FACTS
Private respondent Reginaldo Y. Lim, after his family transferred residence, continued to utilize Room 301 in a building owned by petitioner corporation to store his belongings. As an occupant, he was given a key to the common main door. On September 30, 1987, Lim discovered the main door lock had been changed, and his key no longer worked, preventing his access to the room. He demanded a new key from the corporation’s officer-in-charge but was refused. Lim then filed a complaint in the Metropolitan Trial Court (MeTC) praying for a writ of preliminary mandatory injunction to compel the delivery of the appropriate key, and for actual damages and attorney’s fees.
Petitioner corporation moved to dismiss the complaint, arguing the MeTC lacked jurisdiction. It contended the action was not one for forcible entry or unlawful detainer under Rule 70, but essentially one for specific performance to enforce a contractual right to a key, which falls under the general jurisdiction of the Regional Trial Court. The MeTC denied the motion to dismiss, and the Court of Appeals upheld this denial.
ISSUE
Whether the MeTC has jurisdiction over the complaint, specifically, whether the action is one for forcible entry or unlawful detainer within its exclusive original jurisdiction.
RULING
Yes, the MeTC has jurisdiction. The Supreme Court ruled that the complaint, regardless of its caption or prayers, constitutes an action for forcible entry under Rule 70. The Court emphasized that jurisdiction is determined by the allegations in the complaint and the nature of the relief sought. The core allegations reveal that Lim was in prior physical possession of Room 301, which he used as a storage space, and that the corporation, through stealth (by changing the lock without his consent), deprived him of that possession by preventing his ingress. The deprivation of possession occurred within one year prior to the filing of the complaint, satisfying the jurisdictional requirement for forcible entry.
The legal logic is that an action for forcible entry is available to any person, including a lessee or occupant, who is unlawfully deprived of possession of any land or building by force, intimidation, threat, strategy, or stealth. The corporation’s act of changing the lock constituted “strategy or stealth” that effectively ousted Lim from his possession. The prayer for a mandatory injunction to restore his access by providing a key is precisely the relief proper in a forcible entry case—to restore the plaintiff to possession. The claim for damages is merely incidental to the main action for restitution. Therefore, the MeTC correctly assumed jurisdiction.