TOPIC Jurisdiction

CASE NO. G.R. No. 176405

CASE NAME Leo Wee v. George and Martiniana De Castro
MEMBER Apa

DOCTRINE
• The barangay justice system was established to ease decongestion in the courts by helping the
parties reach settlements. It became compulsory and is required as a condition precedent to file a
complaint before a court.
• What determines the nature of an action and the court that has jurisdiction are the allegations in
the complaint and the character of the relief sought. Despite the failure to use to the words
“unlawful withholding,” the allegations in the complaint are able to establish this fact.

RECIT-READY DIGEST
Respondents de Castro filed a complaint before the MTC of Alaminos arguing that petitioner Wee refused
to pay the rent over his property. The dispute on the rents was then brought to the Lupon. Since the
parties failed to settle, the Lupon issued a certification authorizing the dispute to be referred to the courts.

Later, de Castro terminated his lease agreement with Wee. Since Wee refused to vacate, de Castro filed an
action for ejectment before the MTC without going to the Lupon.

In his defense, Wee argues that the MTC has no jurisdiction because of the failure to comply with the
jurisdictional requirement of going to the Lupon first. (Note: The issue brought to the Lupon was the
dispute on the rentals, and not the issue as to the ejectment suit)

WON the de Castros failed to comply with the condition precedent of going to the Lupon first. (NO)
While the Certification issued by the Lupon refers to the issue on increased rents, it was sufficient to
include the issue on the ejectment of Wee. Given the facts of the case, the conciliation proceedings for the
amount of rent should logically and reasonably include the matter of possession of the property subject of
the lease agreement.

Under Art. 1687 of the Civil Code, “if the period for the lease has not been fixed… it is understood be
monthly if the rent is from month to month.” In this case, since the rentals are being paid monthly, the
period of lease terminates at the end of each month. Thus, the de Castros have the right to demand the
ejectment of Wee. Without a lease contract, Wee has no right of possession and must vacate the same.
The De Castros should be allowed to file an action for ejectment before the MTC to recover possession

WON the de Castro failed to establish the jurisdictional fact of “unlawful withholding. (NO)
What determines the nature of an action and the court that has jurisdiction are the allegations in the
complaint and the character of the relief sought. The complaint of the de Castros sufficiency allege that
Wee’s possession of their property was originally lawful and his right thereto expired. Despite the failure
to use the term “unlawful withholding,” the complainant’s allegations amounted to an unlawful
withholding.

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FACTS
• Respondents de Castro filed a complaint before the MTC of Alaminos alleging that they are the
owners of a building and lot in Pangasinan which they rented to petitioner Wee on a month-to-
month basis for P9000 per month.
• The parties agreed that starting October 2001 the payment will be increased to P15,000. Wee
refused to pay the increased rent when it became due.
• The dispute on the increase of rents was then brought to the Lupon; however, the parties failed
to settle amicably. The Lupon then issued a certification authorizing the dispute to be brought to
the court.
• Later, de Castro sent a letter to Wee terminating their lease agreement and demanding that the
latter vacate and turnover the property. Since Wee refused to vacate, Respondent George de
Castro, together with his co-respondents Annie, Felomina, and Jesus (all surnamed de Castro)
instituted an action for ejectment before the MTC.
• In his defense, Wee countered: (1) that there was no agreement to increase the rent, (2) that the
respondents failed to comply with the jurisdictional requirement of conciliation before the
Barangay Lupon, and (3) that the MTC lacked jurisdiction over the ejectment suit since the
complaint failed to allege an “unlawful withholding” of the property.
• MTC: Dismissed the complaint for failure to comply with the conciliation requirement before the
Lupon.
• RTC: Affirmed the MTC.
• CA: Reversed the RTC and ordered Wee to cavate the property and turn it over to respondents de
Castro.
• In this petition, Wee argues that the failure to go through the Lupon constitutes a jurisdictional
defect.

WON the Certification issued by the Lupon stating that no settlement was reached by the parties on the
issue on increased rents, and not the issue on ejectment, was sufficient to comply with the
requirement.(YES)

The barangay justice system was established to ease decongestion in the courts by helping the parties
reach settlements. It became compulsory and is required as a condition precedent to file a complaint
before a court.

While the Certification issued by the Lupon refers to the issue on increased rents, it was sufficient to
include the issue on the ejectment of Wee. Given the facts of the case, the conciliation proceedings for the
amount of rent should logically and reasonably include the matter of possession of the property subject of
the lease agreement.

Under Art. 1687 of the Civil Code, “if the period for the lease has not been fixed… it is understood be
monthly if the rent is from month to month.” In this case, since the rentals are being paid monthly, the
period of lease terminates at the end of each month. Thus, the de Castros have the right to demand the
ejectment of Wee. Without a lease contract, Wee has no right of possession and must vacate the same.
The De Castros should be allowed to file an action for ejectment before the MTC to recover possession.

WON the failure of the De Castros to establish the jurisdictional requirement of “unlawful withholding”
is fatal to their cause of action. (NO)

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What determines the nature of an action and the court that has jurisdiction are the allegations in the
complaint and the character of the relief sought. The complaint of the de Castros sufficiency allege that
Wee’s possession of their property was originally lawful and his right thereto expired. Despite the failure
to use the term “unlawful withholding,” the complainant’s allegations amounted to an unlawful
withholding.

DISPOSTIVE PORTION
WHEREFORE, the petition is DENIED.