| Category | Summary |
| Facts | Plaintiffs (Rosario, et al.), claiming ownership and prior possession of a parcel of land, filed a complaint in the Court of First Instance (CFI) on October 16, 1952, alleging that the defendants (Carandang, et al.) illegally entered the premises, destroyed nipa plants, and took possession on or about October 3, 1952. The plaintiffs sought P2,000 in damages resulting from the illegal possession and destruction, plus an additional P500 for expenses incurred in filing the case. The defendants moved to dismiss, arguing the action was one of forcible entry and detainer, exclusively cognizable by the Justice of the Peace (JP) Court, and that the damages claimed were not sufficient to confer jurisdiction on the CFI. The CFI dismissed the case. Plaintiffs attempted to cure the defect by moving to admit an amended complaint, which specifically alleged that the defendants were claiming ownership in related land registration cases, but the CFI denied this motion, leading to the appeal. |
| Issues | 1. Whether the original complaint, filed two weeks after illegal entry and seeking recovery of possession and P2,000 in damages, was a case of forcible entry and detainer falling under the exclusive jurisdiction of the Justice of the Peace Court. 2. Whether a court, having determined it lacked jurisdiction over the subject matter of the original complaint, can subsequently allow the amendment of that complaint to confer jurisdiction. |
| Ruling | “In view of the foregoing, the orders appealed from are affirmed, without prejudice to appellants’ filing another case for reivindicacion. Costs against appellants.”. |
| Essential Elements of Jurisprudence | Controlling Doctrines and Legal Principles: 1. Ejectment Jurisdiction: An action alleging prior possession and deprivation thereof within the period of one year by illegal entry and withholding of possession falls within the exclusive and original jurisdiction of the justice of the peace courts (Rule 72, Sec. 1, Rules of Court; Sec. 88, Rep. Act 296). 2. Test for Jurisdiction: Jurisdiction is determined and conferred by the allegations of the complaint, and not the prayer. The simple allegation that defendants opposed a land registration application does not automatically convert the case into one of ownership. 3. Effect of Damages Claim on Ejectment: Justice of the Peace courts have exclusive jurisdiction over forcible entry and detainer cases, regardless of the amount claimed therein as damages. 4. Exclusion of Litigation Costs: Expenses for the filing of the suit, such as costs and attorneys’ fees (e.g., the additional P500 claimed), are excluded from the jurisdictional amount that confer jurisdiction upon courts. 5. Jurisdiction Cannot Be Conferred by Amendment: When the original complaint shows on its face that the Court has no jurisdiction over the subject-matter of the case, an amendment of the complaint can not be allowed so as to confer jurisdiction upon the Court. 6. Prerequisite to Valid Action: It is elementary that the court must first acquire jurisdiction over the case in order to act validly therein (including ruling on a motion to amend). (An exception exists if the amendment is made as a matter of right before an answer or motion to dismiss is filed, in which case the amendment supersedes the original pleading). |
| Sample Q&A | Q: Fifteen days after being unlawfully deprived of possession of his farmland, Plaintiff P files a complaint with the Court of First Instance (CFI), labeling it as a “declaration of ownership” and seeking P3,000 in damages (P2,000 for crops destroyed and P1,000 for litigation expenses). P also includes a paragraph mentioning that the defendant is an oppositor in P’s land registration case. The CFI dismisses the action for lack of jurisdiction, finding it to be a forcible entry case. P then moves to amend the complaint to clearly allege a title dispute. Should the CFI admit the amended complaint and assume jurisdiction? A: No. The CFI should not admit the amended complaint. Based on the principles established in Rosario v. Carandang, the original complaint, filed within one year (15 days) of the dispossession, is clearly an action for forcible entry and detainer (Rule 72, Sec. 1, Rules of Court). Jurisdiction is determined by the allegations, not the prayer or the label of the action. Forcible entry falls under the exclusive jurisdiction of the inferior court, regardless of the damages claimed. Furthermore, litigation expenses (P1,000) are excluded from the jurisdictional amount. Since the CFI never acquired jurisdiction over the subject matter through the original fatally defective pleading, it lacks the power to allow an amendment intended to confer jurisdiction upon itself. The proper recourse for P is to file a new complaint for reivindicacion (recovery of ownership) in the appropriate court, or file the forcible entry action in the inferior court. |
Jurisdiction #ForcibleEntry #Ejectment #AmendmentOfPleadings #RosariovsCarandang #CivilProcedure #RulesOfCourt #JurisdictionalAmount #AccionReivindicatoria #PhilippineLaw #RemedialLaw #SupremeCourtPH #CaseDigestPH #JurisprudencePH #LawStudentPH #BarExamsPH #FilipinoLawyer #LegalEducationPH #LawSchoolPH #IntegratedBarOfThePhilippines #LegalInsights #KnowYourRightsPH #LawPH #LegalTips #PropertyLaw #CourtProcedure #JusticeSystemPH #LawyerLife #LegalPH #Philippines
Leave a Reply