GR L 37048; (November, 1988) (Digest)
G.R. No. L-37048 November 23, 1988
NICOLAS LAURENTE, petitioner, vs. THE COURT OF APPEALS and MANOTOK REALTY, INC., respondents.
FACTS
Manotok Realty, Inc. filed an action for recovery of possession and damages against Nicolas Laurente before the Court of First Instance of Manila. Manotok alleged it was the registered owner of a parcel of land in Sta. Cruz, Manila, covered by Transfer Certificates of Title, having acquired it in 1959. It claimed Laurente had been in material and physical possession of the lot for over a year prior to the complaint’s filing, without its consent, causing monthly rental damages. Laurente, in his answer, denied the allegations and asserted special defenses. He claimed the land he possessed was different, that Manotok was a purchaser in bad faith aware of his prior possession, and that Manotok’s action was barred by laches. He also presented a counterclaim for the value of improvements he introduced on the land. The trial court ruled in favor of Manotok, ordering Laurente to vacate and pay rentals and attorney’s fees. The Court of Appeals affirmed the decision.
ISSUE
The primary issues were: (1) whether the Court of First Instance had jurisdiction over the action, and (2) whether Laurente could be considered a possessor in good faith entitled to reimbursement for improvements.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision. On jurisdiction, the Court held it is axiomatic that the allegations in the complaint determine the nature of the action and the court’s jurisdiction. Manotok’s complaint alleged Laurente had been in possession for over a year, which placed the action within the realm of an accion publiciana for recovery of right of possession, falling under the jurisdiction of the Court of First Instance, not an ejectment case within a municipal court’s jurisdiction. The allegation of possession for over a year was controlling.
On the substantive issue, the Court found no error in the Court of Appeals’ factual conclusions. It upheld the finding that Manotok established its ownership through certificates of title and documents showing its acquisition at a public auction. Laurente’s evidence, particularly Exhibit “1” (a receipt for P100.00 paid to Don Vicente Legarda), did not prove ownership or establish him as a possessor in good faith. The appellate court reasonably interpreted this payment, alongside Laurente’s own admission that he knew he was not the owner when he built his house, as indicative that he was at best a lessee. As such, he could not invoke Article 448 of the Civil Code on reimbursement for useful improvements. The Supreme Court emphasized it is not a trier of facts and found no special circumstance warranting a reversal of the factual assessments made by the Court of Appeals, which are generally conclusive.