de Leon Vs CA
de Leon Vs CA
de Leon Vs CA
DE LEON
vs.
(245 SCRA 166)Facts: Jesus Jalbuena entered into a verbal lease contract with Uldarico Inayan, for one
yearrenewable for the same period. Inayan was allowed to continue with the lease from year to
year.Corazon Jalbuena de Leon is the daughter of Jesus and the transferee of the subject property.
Inayanceased paying the agreed rental and instead, asserted dominion over the land. When asked by
De Leonto vacate the land, he refused to do so, prompting De Leon to file a complaint before the RTC
for"Termination of Civil Law Lease; Recovery of Possession, Recovery of Unpaid Rentals andDamages.
Inayan claimed tenancy dispute thus the lower court issued an order adopting the procedure in agrarian
cases but still rendered decision Declaring the lease contract between plaintiffand defendant as a civil
law lease, and that the same has already been terminated due to defendant'sfailure to pay his rentals
from 1983 up to the present.On appeal to the CA, Inayan raised the sole issueof jurisdiction and alleged
that the lower court, acting as Court of Agrarian Relations, had no jurisdiction over the action. The CA,
at first affirmed the trial court's decision, but when an MR filed by Inayan it then set aside its earlier
decision and dismissed the civil case for want of jurisdiction. Inits amended decision, the appellate court
held that petitioner's complaint below was anchored on
acción interdictal
, a summary action for recovery of physical possession that should have been brought before the proper
inferior court.Issue: Whether or not the RTC then acting as a court of agrarian relations employing
agrarian procedure had jurisdiction to try the suit filed by De Leon?-Held: Yes. Jurisdiction of the
court over the subject matter is conferred only by the Constitution or bylaw. It is determinable on
the basis of allegations in the complaint.In order to determine whether the court below had jurisdiction,
it is necessary to first ascertainthe nature of the complaint filed before it. A study of the complaint
instituted by petitioner in thelower court reveals that the case is, contrary to the findings of the
respondent appellate court, not oneof unlawful detainer.
Not being merely a case of ejectment, the regional trial court possessed jurisdiction to try and resolve
the case