G.R. No. 195477. January 25, 2016.

*
SPOUSES HERMINIO E. ERORITA and EDITHA C. ERORITA, On June 4, 2007, the RTC ruled in favour of spouses Dumlao. It
petitioners, vs. SPOUSES LIGAYA DUMLAO and ANTONIO ordered the defendants (1) to immediately vacate the property and
DUMLAO, respondents. Erorita vs. Dumlao, 781 SCRA 551, G.R. turn it over to the Spouses Dumlao, and (2) to pay accumulated
No. 195477 January 25, 2016 rentals, damages, and attorney’s fees. The RTC also prohibited the
defendants from accepting enrolees to the San Mariano Academy.
Brion, J.
Facts:
The defendants Erorita then appealed to the CA arguing that the
Spouses Antonio and Ligaya Dumlao (Spouses Dumlao) are the
complaint is a case for unlawful detainer in which the RTC had no
registered owners of a parcel of land located at Barangay San
jurisdiction over the subject matter of the case.
Mariano, Roxas, Oriental Mindoro, and covered by TCT No. T-
53000 in which San Mariano Academy structures are built.
CA affirmed the RTC’s decision.
On April 25, 1990, Spouses Dumlao bought the property in an
extrajudicial foreclosure sale when Spouses Herminio and Editha
Petitioner’s Argument in SC
Erorita (Spouses Erorita) former owners, failed to redeem it. With
the consent of Spouses Dumlao, it however allowed Spouses Erorita
to continue to operate the school and to appoint Hernan and Susan
Erorita as the school’s administrators. Spouses Erorita argued that: (a) the RTC had no jurisdiction because
the complaint shows a case for unlawful detainer; and (b) Hernan
and Susan were improperly impleaded as parties to this case.
On December 16, 2002, Spouses Dumlao asked the petitioners to
vacate the property for they had failed to pay monthly rent of Twenty
Thousand Pesos (P20,000.00) since 1990. The Spouses Erorita Respondent’s Argument inSC
however countered that the Dumlaos allowed them to continue to run
the school without rental out of goodwill and friendship.
The respondents argued that: (a) the RTC had jurisdiction because
the case involves issues other than physical possession; (b) even
On March 4, 2004, the Spouses Dumlao filed a complaint for assuming the RTC initially had no jurisdiction, the petitioners’ active
recovery of possession before the Regional Trial Court (RTC) participation during the proceedings bar them from attacking
against the defendants Hernan, Susan, and the Spouses Erorita. jurisdiction; (c) Hernan and Susan are real parties in interest as the
lease contract’s primary beneficiaries; and (d) this last issue cannot value. Erorita vs. Dumlao, 781 SCRA 551, G.R. No. 195477 January
be raised for the first time on appeal. 25, 2016

Issue: Whether or not the RTC had jurisdiction to hear and decide on
the case
Held:
Remedial Law; Civil Procedure; Jurisdiction; The allegations in the
complaint determine the nature of an action and jurisdiction over the
case.—The allegations in the complaint determine the nature of an
action and jurisdiction over the case. Jurisdiction does not depend on
the complaint’s caption. 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. Erorita vs.
Dumlao, 781 SCRA 551, G.R. No. 195477 January 25, 2016
Same; Same; Same; Under Republic Act (RA) No. 7691, an action
for unlawful detainer is within the Municipal Trial Court’s (MTC’s)
exclusive jurisdiction regardless of the property’s assessed value.—
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. Erorita vs. Dumlao, 781 SCRA 551, G.R. No. 195477 January
25, 2016
Same; Same; Same; Under Republic Act (RA) No. 7691, an action
for unlawful detainer is within the Municipal Trial Court’s (MTC’s)
exclusive jurisdiction regardless of the property’s assessed value.—
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