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Balibago Faith Baptist Church, Inc. vs. Faith in Christ Jesus Baptist Church, Inc.

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Balibago Faith Baptist Church, Inc. vs. Faith in Christ Jesus Baptist Church, Inc.

Case Title and Citation

Balibago Faith Baptist Church, Inc. and Philippine Baptist S.B.C., Inc., petitioners, vs. Faith in Christ Jesus Baptist Church, Inc. and Reynaldo Galvan, respondents.
G.R. No. 191527, August 22, 2016
Supreme Court - Third Division
Ponente: Justice Peralta

Facts

  • Petitioners PBSBC (registered owner) and BFBC alleged they acquired and possessed Lot 3, Block 35 (LRC PCS-2364), covered by TCT No. 82587, located at 35-3 Sarita St., Diamond Subdivision, Balibago, Angeles City.
  • On March 7, 1990, PBSBC granted a contract of simple loan to BFBC to enable BFBC to purchase the subject property; BFBC took possession and held religious services there.
  • While BFBC occupied the premises, respondent Reynaldo Galvan and companions purportedly joined services; BFBC alleged Galvan later formed and incorporated FCJBC and took control of the property.
  • Luzon Convention of Southern Baptist Churches, Inc. (LCSBC) sent a letter dated September 5, 2001 recognizing BFBC’s right to the premises and BFBC’s pastor.
  • BFBC sent a demand letter dated September 4, 2002, demanding FCJBC to vacate within five days and to pay ₱10,000.00 per month as compensation beginning October 2001.
  • On September 24, 2003, BFBC and PBSBC filed a Complaint for unlawful detainer and damages against FCJBC and Galvan in MTC, Branch 2, Angeles City (Civil Case No. 02-388).
  • FCJBC answered, alleging prior existence since 1984 (as Faith Baptist Church), that it paid installments (including ₱10,000.00 on May 30, 2001) and asserted willingness to pay remaining balance of ₱240,615.53; it filed a Petition for Consignation of Payment on October 9, 2002 in RTC Branch 62 (Civil Case No. 10713).
  • On February 9, 2004, the MTC ruled for BFBC, treating the action as forcible entry and ordering defendants to vacate within three months, pay attorney’s fees and costs.
  • The RTC, on April 19, 2006, affirmed the MTC decision; motion for reconsideration denied on November 24, 2006.
  • The Court of Appeals, in a Decision dated March 5, 2010 in CA-G.R. SP No. 97292, granted FCJBC’s petition and dismissed the unlawful detainer complaint.
  • Petitioners filed a Rule 45 petition seeking reversal of the CA decision.

Issues

  1. Did the Court of Appeals err in dismissing the complaint for unlawful detainer and ruling that the MTC has no jurisdiction over the case?
  2. Did the Court of Appeals err in raising issues on the sufficiency of the complaint and the MTC’s jurisdiction which were not raised by the parties?
  3. Did the Court of Appeals err in dismissing the complaint instead of deciding the case on the merits in light of Section 8, Rule 140 of the Rules of Court?

Ruling

  1. No - The Court of Appeals did not err; the complaint was defective and the MTC lacked jurisdiction.
  2. No - The Court of Appeals properly considered jurisdictional defects sua sponte.
  3. No - Dismissal was appropriate because the complaint failed to allege essential facts establishing the summary action and jurisdiction.

Reasoning / Ratio Decidendi

  • The Court reiterated the distinction between forcible entry and unlawful detainer: forcible entry is deprivation of possession by force, intimidation, threat, strategy, or stealth and involves possession illegal from the start; unlawful detainer involves prior lawful possession that becomes unlawful after expiration or termination of the right to possess. (See Sumulong v. Court of Appeals, G.R. No. 108817, May 10, 1994, 232 SCRA 372.)
  • The nature of the cause of action and the court’s jurisdiction are determined by the allegations in the complaint, not by its caption. A complaint in summary proceedings must show on its face the facts that confer jurisdiction without resort to parol testimony. (See Dela Cruz v. Court of Appeals; Zacahas v. Anacay, G.R. No. 202354, September 24, 2014, 736 SCRA 508.)
  • A complaint for unlawful detainer must allege: 1) defendant’s initial possession was by contract or tolerance of plaintiff; 2) plaintiff terminated that right by notice; 3) defendant remained in possession and deprived plaintiff of enjoyment; and 4) the action was filed within one year from last demand. (See Cabrera v. Getaruela, 604 Phil. 59 (2009).)
  • BFBC’s complaint alleged prior possession but also alleged that defendants “took control” and that occupancy was unlawful prior to demand, which is inconsistent with unlawful detainer elements and suggests forcible entry. Where allegations describe entry unlawful from the start, the action is forcible entry, which has different requirements and prescriptive period. (See Sumulong; Mediran v. Villanueva; David v. Cordova.)
  • Even if treated as forcible entry, the complaint failed to allege when or how dispossession occurred (force, intimidation, stealth, etc.), an essential allegation to invoke summary forcible-entry remedy and to determine the one-year period for bringing the action. Absent such allegations, the complaint did not establish MTC jurisdiction. (See Nunez v. SLTEAS Phoenix Solutions, Inc.; Spouses Ong v. Parel.)
  • Jurisdictional defects may be raised at any stage, including on appeal; lack of jurisdiction renders judgment void. Therefore, the Court of Appeals properly addressed the insufficiency and dismissed the complaint for want of jurisdiction. (See Zacahas v. Anacay.)

Doctrine / Legal Principle

  • The character and jurisdiction of an action are determined by the allegations in the complaint, not by its caption.
  • Forcible entry and unlawful detainer are distinct causes of action with different elements and different prescriptive rules.
  • Summary courts require the complaint to show jurisdiction on its face; failure to allege essential facts deprives the court of jurisdiction.
  • Courts may raise and decide jurisdictional issues sua sponte at any stage; lack of jurisdiction is fatal and renders resulting judgments void.

Disposition

  • The petition for review on certiorari is DENIED.
  • The Decision of the Court of Appeals dated March 5, 2010 in CA-G.R. SP No. 97292 is AFFIRMED in toto.
  • Effect: the unlawful detainer complaint was dismissed for lack of jurisdiction; the MTC and RTC judgments affirming possession were negated insofar as they rested on an insufficient complaint.

Concurring / Dissenting Opinions

  • Justice Velasco, Jr. (Chairperson), Justice Perez, Justice Reyes, and Justice Jardeleza concurred with the ponente. No dissent noted.

Significance / Notes

  • Pleadings in summary possessory actions must allege facts establishing either unlawful detainer or forcible entry; inconsistent or conclusory allegations that fail to state how and when dispossession occurred are fatal.
  • Where a complaint’s allegations indicate forcible entry but fail to allege the manner and time of dispossession, the appropriate remedy may be a plenary action in the RTC rather than summary proceedings in the MTC.
  • Jurisdictional questions are fundamental and may be raised by a court at any stage; parties cannot cure a jurisdictionally defective complaint by asserting defenses or filing motions.
  • Practitioners should plead with specificity the factual elements required by Rule 70 (forcible entry) or the unlawful detainer standards to secure summary relief and to establish the proper forum.
Remedial Law Civil Procedure Property Law
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