Scribd
Upload
39 views2 pages

Tagalog vs. Vda. de Gonzales

The Supreme Court ruled that the Regional Trial Court (RTC) lacked jurisdiction over a case involving Lot No. 1595-A in Cebu, which was determined to be an unlawful detainer suit that should fall under the Municipal Trial Court's (MTC) jurisdiction. The RTC's decision was set aside, and the case was dismissed without prejudice due to the jurisdictional error. The ruling emphasized that jurisdiction is determined by the nature of the complaint and that unlawful detainer cases are exclusively under the MTC's authority if dispossession has lasted less than one year.

Uploaded by

Mariah Kaye Briones
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
39 views2 pages

Tagalog vs. Vda. de Gonzales

The Supreme Court ruled that the Regional Trial Court (RTC) lacked jurisdiction over a case involving Lot No. 1595-A in Cebu, which was determined to be an unlawful detainer suit that should fall under the Municipal Trial Court's (MTC) jurisdiction. The RTC's decision was set aside, and the case was dismissed without prejudice due to the jurisdictional error. The ruling emphasized that jurisdiction is determined by the nature of the complaint and that unlawful detainer cases are exclusively under the MTC's authority if dispossession has lasted less than one year.

Uploaded by

Mariah Kaye Briones
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 2

Title Tagalog vs. Vda.

de Gonzales

Case G.R. No. 201286

Decision Date Jul 18, 2014

A dispute over Lot No. 1595-A in Cebu led to a jurisdictional error; the SC ruled the RTC lacked authority,
as the case was for unlawful detainer, falling under MTC jurisdiction.

Facts:

Subject of Litigation

The case involves Lot No. 1595-A, a parcel of land in Buanoy, Balamban, Cebu, with an area of 27,551
square meters, covered by Transfer Certificate of Title (TCT) No. T-57604.

Parties Involved

Petitioner: Inocencia Tagalog


Respondents: Maria Lim Vda. de Gonzalez, Gaudencia L. Buagas, Ranulfo Y. Lim, Don L. Calvo, Susan
C. Santiago, Dina C. Aranas, and Rufina C. Ramirez.

Initial Complaint

On 5 February 2003, respondents filed a Complaint for Recovery of Possession, Preliminary Mandatory
Injunction with a Prayer for a Temporary Restraining Order with Damages and Attorney’s Fees against
Tagalog. Respondents alleged they were co-owners of the land and that Tagalog occupied a portion as a
lessee under a verbal month-to-month lease. Tagalog built a house on the land, which was damaged by a
typhoon, after which she stopped paying rent and vacated the premises.

Demand to Vacate and Construction of New House

In December 2002, respondents demanded Tagalog remove debris and vacate the land, asserting the
lease was terminated. However, in January 2003, Tagalog constructed a two-story residential house on
the land without respondents' consent or a building permit. Despite warnings from the Municipal Engineer
and Barangay Captain, Tagalog continued the construction.

Tagalog’s Defense

Tagalog claimed the lease was still valid and subsisting, denied being notified of respondents' intent to
use the land, and stated she had permission to repair her dwelling without enlarging the area. She prayed
for the dismissal of the case, arguing it was for unlawful detainer, which was beyond the RTC’s
jurisdiction.

RTC Decision

On 5 May 2008, the RTC ruled in favor of respondents, ordering Tagalog to vacate the premises, pay
moral damages, and attorney’s fees.

Appeal to the Court of Appeals

Tagalog appealed, but the CA dismissed the case for failure to file the required brief. Her motion for
reconsideration was also denied.

Issue:

The main issue is whether the Regional Trial Court (RTC) had jurisdiction over the subject matter of the
action.
Ruling:

The Supreme Court granted the petition, holding that the RTC lacked jurisdiction. The case was for
unlawful detainer, which falls under the jurisdiction of the Municipal Trial Court (MTC). The RTC’s
decision and subsequent resolutions by the CA were set aside, and the case was dismissed without
prejudice.

Ratio:

1. Jurisdiction Determined by the Nature of the Complaint: The jurisdiction of a court is


determined by the nature of the action pleaded in the complaint.

2. Unlawful Detainer Defined: Unlawful detainer involves withholding possession of land or


building after the expiration or termination of the right to hold possession under a contract,
express or implied.

3. MTC’s Exclusive Jurisdiction: Ejectment suits, including unlawful detainer, are within the
exclusive jurisdiction of the MTC if dispossession has lasted for not more than one year.

4. RTC’s Error in Taking Jurisdiction: The RTC erred in taking jurisdiction over the case, as it was
clearly an unlawful detainer suit based on the expiration of a month-to-month verbal lease.

5. Void Proceedings: Proceedings before a court without jurisdiction, including its decisions, are
null and void.

You might also like