**Crispina Unida, et al. vs. Heirs of Ambrosio Urban, G.R. No. 149765, September 9, 2003**
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### Facts
1. **Complaint Filed**: On March 3, 1998, the “Heirs of Ambrosio Urban,” represented by Lucio Cabaddu, filed a complaint for unlawful detainer against Crispina Unida, Nancy Unida, Edwin Damo, Andrew Mabalot, Ricardo Damo, and Jocelyn Damo at the Municipal Trial Court (MTC) of Camalaniugan, Cagayan. The respondents claimed ownership of subdivided Lots 298, 299, and 616 and alleged that the petitioners unlawfully entered and cultivated these lands without permission, starting around ten years ago.
2. **Defendants’ Answer**: In their answer, the defendants denied the validity of Lucio Cabaddu’s authority to represent the plaintiffs and claimed they and their predecessors-in-interest had possessed the land since time immemorial. They also asserted that the title held by the respondents (OCT No. P-48306) was fraudulently obtained.
3. **MTC Decision**: On June 7, 1999, the MTC ruled in favor of the respondents, finding that the respondents tolerated the petitioners’ stay and cultivation and that the respondents were the lawful owners of the land.
4. **RTC Appeal**: The petitioners appealed to the Regional Trial Court (RTC) of Cagayan, questioning both Lucio Cabaddu’s authority and asserting their long-standing possession and ownership of the land since pre-war times, inherited from their father, Luis Unida.
5. **RTC Decision**: On October 26, 1999, the RTC reversed the MTC’s decision, stating that although Lucio Cabaddu obtained an SPA, it lacked specific authorization to file the complaint. Additionally, the RTC found that the case was neither an unlawful detainer nor forcible entry, suggesting that an accion publiciana or reivindicatoria was the proper remedy.
6. **CA Appeal**: The respondents appealed to the Court of Appeals (CA), arguing that Lucio Cabaddu’s SPA cured any defects and that the allegations in the complaint sufficed to demonstrate the unlawful withholding of possession.
7. **CA Decision**: On September 19, 2001, the CA reversed the RTC’s decision and reinstated the MTC’s ruling, asserting that the SPA was sufficient and that the complaints adequately alleged unlawful withholding of possession.
8. **Supreme Court Petition**: The petitioners then filed a Petition for Review on Certiorari to the Supreme Court, maintaining the lack of jurisdiction by the lower courts and emphasizing their ownership and possession rooted in pre-war times.
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### Issues
1. **Jurisdiction and Proper Action**:
– Whether the MTC had jurisdiction over the complaint, given the allegations.
– Whether the proper action was unlawful detainer, given the claim of toleration and long-standing possession.
2. **Authority of Representation**:
– Whether the SPA subsequently obtained by Lucio Cabaddu cured the initial lack of specific authorization to file the complaint.
– Whether Lucio Cabaddu was the real party in interest or had the proper standing to represent the plaintiffs.
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### Court’s Decision
1. **Jurisdiction and Proper Action**:
– The Supreme Court found that the MTC did not have jurisdiction over the case because the respondents’ alleged “toleration” of the petitioners’ presence was not the form of toleration contemplated by law in unlawful detainer cases. The respondents admitted the petitioners’ possession was unlawful from the beginning, thus an action for unlawful detainer was improper.
– Neither could the case be considered one for forcible entry, as there were no allegations of entry by force, intimidation, threats, stealth, or strategy. Consequently, the MTC had no jurisdiction over the case.
2. **Authority of Representation**:
– The Supreme Court determined that, procedurally, Lucio Cabaddu was properly designated as a representative pursuant to legal requirements, although the discussion on his representation became moot due to the case’s dismissal for lack of jurisdiction.
Given the finding of lack of jurisdiction, the Supreme Court reversed and set aside the CA’s decision and directed the RTC to act according to Sec. 8, Rule 40 of the Rules of Court, potentially retrying the case on merit if it had original jurisdiction.
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### Doctrine
1. **Jurisdictional Requirement in Ejectment Cases**:
– For unlawful detainer cases, the plaintiff must demonstrate that their toleration of the defendant’s possession was present from the start; otherwise, the remedy lies in a different legal action such as accion publiciana or reivindicatoria.
2. **Representative as Parties**:
– Compliance with procedural rules for representation, such as those described in Sec. 3, Rule 3 of the Rules of Court, is requisite for a representative to prosecute or defend an action.
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### Class Notes
– **Ejectment Lawsuits**: Understand the distinctions between unlawful detainer and forcible entry and the appropriate actions associated with each.
– **Representation and Real Party in Interest**: Familiarize with legal provisions governing the ability of representatives to initiate a lawsuit.
– **Jurisdiction**: Recognize jurisdictional prerequisites and procedural requirements; in this context, compliance with rule sets such as Sec. 8, Rule 40 of the Rules of Court is crucial.
Statutes:
– **Rule 3, Section 3 of the Rules of Court**: Pertains to representation as parties.
– **Rule 40, Section 8 of the Rules of Court**: Guidelines for cases dismissed for lack of jurisdiction.
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### Historical Background
This case reflects the nuanced interpretation of jurisdiction in property disputes in the Philippine legal system. It exemplifies the historical tension between local agrarian disputes and established legal principles, particularly in regions affected by socio-political instability like those involving insurgent activities. The ultimate decision underscores the necessity of precise procedural and jurisdictional compliance in ejectment actions.
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