GR L 64325; (October, 1985) (Digest)
G.R. No. L-64325 October 3, 1985
CMS INVESTMENTS AND MANAGEMENT CORPORATION and LUIS F. SISON, petitioners, vs. THE INTERMEDIATE APPELLATE COURT (First Special Cases Division) and JOSE TAN, respondents.
FACTS
Private respondent Jose Tan entered into an oral contract of lease with petitioner CMS Investment and Management Corporation for a parcel of land in Parañaque, Metro Manila, on January 24, 1978. Tan constructed a building on the land and operated a business, paying monthly rentals. He alleged the lease was for a ten-year period. In 1982, petitioners, through representatives, demanded that Tan vacate the premises. When he refused, petitioners padlocked and enclosed the leased property with barbed wire on June 8, 1982, preventing Tan and his employees from entering.
Tan filed a complaint for damages with a prayer for a preliminary mandatory injunction in the Court of First Instance of Rizal. The court granted the writ. Petitioners moved to dismiss, arguing the court lacked jurisdiction because the action was essentially for forcible entry, which falls under the exclusive jurisdiction of the municipal court. The motion was denied. Petitioners then filed a petition for certiorari and prohibition with the Intermediate Appellate Court, which upheld the trial court’s jurisdiction. Petitioners elevated the case to the Supreme Court via the instant petition.
ISSUE
Whether the trial court correctly assumed jurisdiction over Tan’s complaint for damages with preliminary mandatory injunction, or whether the action was actually one for forcible entry within the exclusive jurisdiction of the municipal court.
RULING
The Supreme Court dismissed the petition, affirming the rulings of the lower courts. The legal logic hinges on the nature of the action as determined by the allegations in the complaint and the relief sought. An action for forcible entry is a summary proceeding designed to restore physical possession to one who has been illegally deprived thereof. Its sole objective is to resolve the issue of possession de facto.
In contrast, Tan’s complaint primarily sought damages for alleged breaches of a contractual lease agreement. He claimed a ten-year lease was violated by the petitioners’ acts of padlocking and fencing, which constituted a disturbance of his contractual right to possess the property for the agreed term. The ancillary prayer for a preliminary mandatory injunction aimed to restore the status quo ante to prevent irreparable injury pending litigation on the main action for damages. The Supreme Court held that where the main relief is for damages arising from a contractual breach, and the issue of possession is intertwined with the resolution of that contract, the action is not merely possessory. Therefore, the regional trial court (then Court of First Instance) properly exercised jurisdiction. The Court found no grave abuse of discretion in the lower courts’ decisions.