GR L 77227; (May, 1988) (Digest)
G.R. No. L-77227. May 9, 1988. COMMANDER REALTY, INC., petitioner, vs. THE COURT OF APPEALS and RUDY VELAYO, INC., respondents.
FACTS:
Respondent Rudy Velayo, Inc. (Velayo) leased a portion of a building from Francisco Villanueva for five years, renewable for another term. Petitioner Commander Realty, Inc. (Commander) later acquired the property. When Velayo sought to renew the lease in 1980, Commander refused, asserting a new contract was necessary. Velayo filed a consignation case, and the Regional Trial Court (RTC) ruled the lease was renewed but ordered graduated rent increases. On appeal, the Intermediate Appellate Court (IAC) deleted the increases, fixing the rent at the original P10,000 monthly, noting Velayo’s substantial improvements to the premises.
Subsequently, Commander filed a separate complaint for damages (the Usurpation Case) in the RTC, alleging wrongful occupation by Velayo from September 1985 and seeking monthly damages of P65,000, plus injunctive relief. Velayo moved to dismiss, arguing the action was essentially for ejectment, falling within the exclusive jurisdiction of the Metropolitan Trial Court. The RTC denied the motion and ordered Velayo to pay or deposit P65,000 monthly. Velayo challenged this via certiorari in the Court of Appeals, which nullified the RTC’s orders.
ISSUE
Whether the Regional Trial Court had jurisdiction over Commander’s complaint for damages, or whether it was an ejectment case cognizable by the inferior court.
RULING
The Supreme Court affirmed the Court of Appeals, ruling the RTC lacked jurisdiction. The nature of an action is determined by the allegations in the complaint. Commander’s pleading sought to recover possession of the leased premises based on Velayo’s alleged wrongful occupation after the lease term, and demanded compensation for such use. This constituted an action for unlawful detainer, as it involved the relationship of landlord and tenant and the right to possess the property. Jurisdiction over such actions, filed within one year from the alleged unlawful withholding, is vested by law in the proper inferior court, not the RTC. The amount of damages claimed does not alter this jurisdictional determination.
The Court, however, proceeded to settle the reasonable compensation for Velayo’s occupation to avoid multiplicity of suits, noting Velayo had already vacated. Considering the original rent, the graduated increases previously set aside, Commander’s own evidence on area rentals, and Velayo’s significant improvements, the Court fixed the reasonable monthly compensation as follows: P15,000 from September 4, 1980 to September 4, 1983; P20,000 from September 4, 1983 to September 4, 1985; and P25,000 from September 4, 1985 to November 30, 1987. Velayo was ordered to pay accordingly.