G.R. No. 96107 June 19, 1995
CORAZON JALBUENA DE LEON, petitioner, vs. HON. COURT OF APPEALS (SPECIAL SECOND DIVISION) and ULDARICO INAYAN, respondents.

FACTS

Petitioner Corazon Jalbuena de Leon, transferee of two parcels of riceland, filed a complaint against private respondent Uldarico Inayan for termination of civil law lease, recovery of possession, unpaid rentals, and damages. The complaint alleged that Inayan, a lessee under a verbal year-to-year lease, ceased paying the annual rental of 252 cavans of palay in 1983 and refused to vacate the land despite demand. Inayan, in his Answer, claimed to be a tenant and holder of Certificates of Land Transfer (CLTs), which were later canceled by the Ministry of Agrarian Reform as erroneously issued. The Regional Trial Court (RTC) of Iloilo City, applying agrarian procedure, ruled in favor of de Leon, declaring the lease terminated and ordering Inayan to vacate and pay arrears.
On appeal, the Court of Appeals initially affirmed the RTC decision with modification. However, upon Inayan’s motion for reconsideration, the appellate court reversed itself in an amended decision. It held that the complaint was essentially an unlawful detainer action (accion interdictal) for recovery of physical possession, which falls under the exclusive original jurisdiction of the proper inferior court (Metropolitan Trial Court), not the RTC. The Court of Appeals found the complaint fatally defective for failing to allege specifically when the demand to vacate was made, a requisite to determine if the one-year period for filing an ejectment suit had been complied with.

ISSUE

Whether the Court of Appeals erred in ruling that the RTC had no jurisdiction over the complaint, characterizing it as an unlawful detainer case within the exclusive jurisdiction of the inferior courts.

RULING

The Supreme Court REVERSED the amended decision of the Court of Appeals and REINSTATED its original decision affirming the RTC. The complaint was not a simple ejectment suit but an action for termination of a civil law lease and recovery of possession, which is incapable of pecuniary estimation and within the jurisdiction of the RTC. The nature of an action is determined by the allegations in the complaint and the relief sought. De Leon’s prayer involved a declaration of lease termination, recovery of unpaid rentals spanning several years, and damages—issues beyond the limited scope of an unlawful detainer suit, which summarily decides only the question of physical possession. Furthermore, Inayan is estopped from challenging jurisdiction. He voluntarily participated in the proceedings, invoked the court’s authority by seeking affirmative relief in his counterclaim, and raised the jurisdictional issue only after an adverse judgment. Jurisprudence holds that a party cannot repudiate a court’s jurisdiction after submitting to it and actively litigating on the merits. Thus, the RTC validly exercised jurisdiction.