HEIRS OF DANILO ARRIENDA VS.

ROSARIO KALAW, RESPONDENTS

G.R. NO. 204314
FACTS: On January 18, 2001, Danilo Arrienda filed against herein respondent and three other
persons a Complaint for unlawful detainer with the MTC of Calauan, Laguna, alleging that: he is the
owner of an 11,635 square-meter parcel of land located along National Road, Barangay Lamot 2,
Calauan, Laguna; the seller of the property warranted that the same is not tenanted and is free from
any occupants or claimants. Despite such warranty, Arrienda later discovered, that a portion of it
was actually being occupied by herein respondent and the other defendants. After talking to
respondent and the other defendants, petitioner allowed them to continue occupying the premises
in which they have settled, subject to the condition that they will immediately vacate the same upon
prior notice by Arrienda that he will be needing it.
ISSUE: Whether or not the RTC has jurisdiction over Arrienda's appeal of the MTC Decision.
RULING: Yes. It bears to reiterate that under Batas Pambansa Bilang. 129 (B.P. Blg. 129), as
amended by Republic Act No. 7691 (RA 7691), RTCs are endowed with original and appellate
jurisdictions. For purposes of the present petition, Section 19 of B.P. Blg. 129, as amended, provides
for the RTCs’ exclusive original jurisdiction in civil cases involving title to or possession of real
property or any interest therein. Finally, in coming up with its Decision, the RTC made an exhaustive
and definitive finding on Arrienda's main cause of action. It is within the RTC's competence to make
this finding in the exercise of its appellate jurisdiction, as it would, in the exercise of its original
jurisdiction.
SPOUSES HERMINIO E. ERORITA and EDITHA C. ERORITA vs. SPOUSES LIGAYA DUMLAO and
ANTONIO DUMLAO
G.R. No. 195477

FACTS: Spouses Antonio and Ligaya Dumlao are the registered owners of a parcel of land located at
Barangay San Mariano, Roxas, Oriental Mindoro, and covered by TCT No. T-53000. The San Mariano
Academy structures are built on the property. The Spouses Dumlao bought the property in an
extrajudicial foreclosure sale on April 25, 1990. Because the former owners, Spouses Herminio and
Editha Erorita, failed to redeem it, the title was consolidated in the buyers’ name. On December 16,
2002, the Spouses Dumlao asked the petitioners to vacate the property. Although the Spouses
Erorita wanted to comply, they could not immediately close the school without clearance from the
Department of Education, Culture, and Sports to whom they are accountable. On March 4, 2004, the
Spouses Dumlao filed a complaint for recovery of possession before the Regional Trial Court
(RTC) against the defendants Hernan, Susan, and the Spouses Erorita.

ISSUE: Whether the RTC had jurisdiction?

RULING: No, the allegations in the complaint determine the nature of an action and jurisdiction
over the case.5Jurisdiction does not depend on the complaint’s caption. 6 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. Thus, although the complaint bears the caption "recovery of
possession," its allegations contain the jurisdictional facts for an unlawful detainer case. Under RA
7691, an action for unlawful detainer is within the MTC’s exclusive jurisdiction regardless of the
property’s assessed value. In the present case, however, the complaint clearly contained the
elements of an unlawful detainer case. Thus, the case should have been filed with the MTC. The RTC
had no jurisdiction over this case.
Fairland Knitcraft Corporation Vs. Arturo Loo Po
G.R. No. 217694; January 27, 2016

FACTS: In a complaint for unlawful detainer, filed before the MeTC, Fairland alleged that it was the
owner of Condominium Unit No. 205 in Cedar Mansion II on Ma. Escriba Street, Pasig City. The said
unit was leased by Fairland to Po by verbal agreement, with a rental fee of P20,000.00 a month, to
be paid by Po at the beginning of each month. From March 2011, Po had continuously failed to pay
rent. For said reason, Fairland opted not to renew the lease agreement anymore.

ISSUE: Whether or not the complaint sufficiently alleges a cause of action for unlawful detainer.

RULING: Yes. A complaint sufficiently alleges a cause of action for unlawful detainer if it recites the
following: (1) initially, possession of the property by the defendant was by contract with or by
tolerance of the plaintiff; (2) eventually, such possession became illegal upon notice by the plaintiff
to the defendant of the termination of the latter's right of possession; (3) thereafter, the defendant
remained in possession of the property, and deprived the plaintiff of the enjoyment thereof; and (4)
within one (1) year from the last demand on defendant to vacate the property, the plaintiff
instituted the complaint for ejectment. There is no question that the complaint filed by Fairland
adequately alleged a cause of action for unlawful detainer.

SPS. ROLANDO AND SUSIE GOLEZ v. HEIRS OF DOMINGO BERTULDO

GR No. 201289, May 30, 2016

FACTS: In 1976, Benito Bertuldo (Benito) sold Lot 1024 to Asuncion Segovia acting for her
daughter, Susie Golez They executed a Deed of Absolute Sale dated December 10, 1976, clearly
indicating the lot's metes and bounds. After the sale, the Sps. Golez started the construction of their
house on Lot 1025, instead of on Lot 1024. On February 17, 2009, the respondents filed
a Complaint for Unlawful Detainer against the Sps. Golez with the Municipal Circuit Trial Court
(MCTC) of President Roxas, Capiz.

ISSUE: whether or not the unlawful detainer case filed by the respondents against the petitioners
was proper.

RULING: No. In the present case, the Sps. Golez's possession of Lot 1025 as unlawful from the
start and bereft of contractual or legal basis. Domingo did not tolerate the possession of Sps. Golez
since he had immediately objected and protested over the construction of Sps. Golez's house on Lot
1025. Notably, the RTC expressly found that there was no tolerance or permission on the part of
Domingo on the construction of the Sps. Golez house on Lot 1025. Since tolerance has not been
effectively alleged in the complaint, the complaint fails to state a cause of action for unlawful
detainer. Therefore, the MCTC had no jurisdiction over the respondents' complaint.

ALICIA Y. LAUREL, substituted by her sole heir and legal representative JUAN MIGUEL Y.
LAUREL, v. FERDINAND M. V ARDELEON

FACTS: On July 23, 2004, petitioner Alicia Y. Laurel filed a Complaint5 for recovery of possession
and ownership and/or quieting of title against respondent Ferdinand M. Vardeleon concerning a
20,306-square meter island in Caticlan, Malay, Aldan. During the scheduled October 12, 2005
hearing, petitioner was present, together with substitute counsel Atty. Roy Villa and her first
witness. Petitioner moved in open court to postpone trial on the ground that there are pending
motions that have to be resolved, and that the substitute lawyer had yet to confer with the witness,
since her true counsel, Atty. De la Vega - who originally interviewed the witness - was not present.
The case was dismissed on the ground of failure to prosecute on petitioner's part, pursuant to
Section 3, Rule 17 of the 1997 Rules of Civil Procedure.

ISSUE: Whether or not the court committed serious error and grave abuse of discretion in
dismissing petitioner's complaint?

RULING: This Court has said that "[t]he fundamental test for non prosequitur is whether, under the
circumstances, the plaintiff is chargeable with want of due diligence in failing to proceed with
reasonable promptitude. There must be unwillingness on the part of the plaintiff to prosecute. The
Court declares that the trial court erred in dismissing Civil Case No. 7249, and the appellate court
should not have affirmed such dismissal. Petitioner's actuations indicate that she was not at all
unwilling to prosecute her case; nor can it be said that - as the trial court puts it - she "refused" to
present her evidence. Far from these, she was indeed more than eager to see her case through.
When she instituted Civil Case No. 7249 in 2004, petitioner was already eighty-one (81) years of
age. Yet, despite her advanced age, the record indicates that petitioner attended the scheduled
hearing of October 12, 2005, together with her counsel and the first witness - only that lawyer who
attended was a mere proxy, and not petitioner's true counsel who previously conferred with the
witness.