Jurisdiction based on allegations in complaint

After the Dumlaos purchased the property in question through a foreclosure sale, they tolerated the Eroritas to continue operating the school which already existed at the time of the sale. The owners alleged that the Eroritas agreed to pay P20,000.00 monthly rental which they denied as they were merely allowed to continue to run the school without rental out of good will and friendship. A complaint for recovery of possession was filed, by the Dumlaos alleging that a demand made in February 12, 2004 where judgment was rendered ordering the Eroritas to vacate. The CA reversed on appeal ruling that the MTC had jurisdiction as the tax declaration did not exceed P20,000.00, citing Barbosa v. Hernandez, G.R. No. 133564, July 10, 2007, 527 SCRA 99.

Is the ruling correct? Why?
ANSWER: No. The MTC had jurisdiction. The allegations in the complaint determine the nature of an action and jurisdiction over the case (Spouses Flores-Cruz v. Spouses Goli-Cruz, G.R. No. 172217, September 18, 2009, 600 SCRA 545). Jurisdiction does not depend on the complaint’s caption (Hilario v. Heirs of Salvador, G.R. No. 160384, April 29, 2005, 457 SCRA 815). Nor is jurisdiction changed by the defenses in the answer; otherwise, the defendant may easily delay a case by raising other issues, then, claim lack of jurisdiction (Spouses Cruz v. Spouses Torres, G.R. No. 121939, October 4, 1999, 316 SCRA 193; Larano v. Calendacion, G.R. No. 158231, June 19, 2007, 525 SCRA 57; Sps. Erorita v. Sps. Dumlao, G.R. No. 195477, January 25, 2016, Brion, J). [Special Lecture Notes in REMEDIAL LAW By: DEAN ED VINCENT S. ALBANO Bar Review Director, Albano Bar Review Center)

Popular Posts