Beruflich Dokumente
Kultur Dokumente
Liceo de Cagayan
Respondent Angeles is one of the registered owners of a parcel of land located in Sampaloc, Manila. This land is
occupied by Galiga from 1979 to 1993 with a lease contract. Salvador alleged that she bought the land from Galiga
who represented the owner.
Angeles then sent a letter to Salvador demanding that Salvador to vacate the property. Angeles then filed a complaint
for ejectment with the MTC of Manila.
MTC rendered its decision in favor of Angeles. Salvador filed an appeal saying that Angeles had not authority at the
time of the filing of the suit. RTC denied the appeal. Petitioner elevated the case to the CA, but CA affirmed the RTC.
Hence, this present petition.
Issue: Diaz's (respondents representative) failure to proof his authority to represent.
Held:
"[i]f a complaint is filed for and in behalf of the plaintiff [by one] who is not authorized to do so, the complaint is not
deemed filed. An unauthorized complaint does not produce any legal effect. Hence, the court should dismiss the
complaint on the ground that it has no jurisdiction over the complaint and the plaintiff."
Pursuant to the foregoing rulings, therefore, the MeTC never acquired jurisdiction over this case and all proceedings
before it were null and void. The courts could not have delved into the very merits of the case, because legally, there
was no complaint to speak of. The court's jurisdiction cannot be deemed to have been invoked at all.
Petition is granted.
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Republic v Batingue Development Corporation
Facts:
Respondent Bantigue Point Development Corporation filed with the RTC an application for original registration of title
over a parcel of land. Petitioner Republic filed its Opposition. Thereafter, the RTC Clerk of Court transmitted motu
proprio the records of the case to the MTC because the assessed value of the property was allegedly less than
100,000. The MTC awarded the land to respondent. On appeal, the CA ruled that since the former had actively
participated in the proceedings before the lower court, but failed to raise the jurisdictional challenge therein, petitioner
is thereby estopped from questioning the jurisdiction of the lower court on appeal.
Issue:
Whether or not the Republic is estopped from questioning the courts jurisdiction
Held:
The rule is settled that lack of jurisdiction over the subject matter may be raised at any stage of the proceedings.
Jurisdiction over the subject matter is conferred only by the Constitution or the law. It cannot be acquired through a
waiver or enlarged by the omission of the parties or conferred by the acquiescence of the court. Consequently,
questions of jurisdiction may be cognizable even if raised for the first time on appeal