Iglesia Evangelica Metodista en las Islas Filipinas (IEMELIF), Inc. vs. Natanael B. Juane

Jurisdiction over an unlawful detainer case is determined exclusively by the allegations of the complaint, not by the defenses raised in a motion to dismiss. A complaint that sufficiently avers the following jurisdictional elements vests the metropolitan trial court with jurisdiction: (1) the plaintiff is a person from whom possession of land or building is unlawfully withheld after the expiration or termination of the right to hold possession by virtue of any contract, express or implied; (2) the defendant is the person unlawfully withholding possession after the expiration or termination of that right; (3) a demand to comply or vacate was made; and (4) the action was commenced within one year from the demand. A defense that the controversy is intra-corporate, based on the defendant’s removal from a church office, does not divest the MeTC of jurisdiction. In an ejectment proceeding, the sole issue is physical or material possession; any claim of ownership—including a challenge to the plaintiff’s corporate personality—is not a proper defense and may be ruled upon only provisionally to determine who is entitled to possession de facto.

IEMELIF, a religious corporation, owned a parcel of land in Tondo, Manila, on which stood its cathedral, the pastor’s residence, and a church school. Natanael B. Juane was a minister and a member of the Highest Consistory of Elders (the church’s board of trustees). In the February 2000 and February 2001 General Conferences, Bishop Nathanael P. Lazaro, the General Superintendent and General Administrator of the cathedral, appointed Juane as Resident Pastor of the Tondo Cathedral Congregation and authorized him to occupy the pastor’s residence. On 3 March 2002, during the concluding Anniversary Service of the 2002 General Conference, Bishop Lazaro announced Juane’s reassignment as Resident Pastor of the Sta. Mesa Congregation, thereby terminating his authority to occupy the Tondo premises. On 10 May 2002, the Highest Consistory of Elders approved Juane’s expulsion as a pastor for defiance and rebellion. Despite these actions, Juane refused to vacate. IEMELIF sent a formal demand to vacate on 23 May 2002 and, after Juane’s continued refusal, filed a complaint for unlawful detainer on 17 September 2002.

• The Parties and the Premises: IEMELIF was a religious corporation and the registered owner of a parcel of land in Tondo, Manila (TCT No. 62080 and TCT No. 14366). On the property stood the IEMELIF Cathedral, the pastor’s residence, and the church’s school. Juane was a former minister and had been elected a member of the Highest Consistory of Elders in February 2000.

• Appointment and Authority to Occupy: During the 2000 and 2001 IEMELIF General Conferences, Bishop Nathanael P. Lazaro, the General Superintendent and General Administrator of the cathedral, announced Juane’s appointment and assignment as Resident Pastor of the Tondo Cathedral Congregation. By virtue of that appointment, Juane was authorized to stay at and occupy the pastor’s residence inside the cathedral complex and took charge of the cathedral facilities.

• Reassignment and Expulsion: On 3 March 2002, at the concluding Anniversary Service of the 2002 General Conference, Bishop Lazaro removed Juane as Resident Pastor of the Tondo Cathedral Congregation and reassigned him as Resident Pastor of the Sta. Mesa (Banal na Hapag) Congregation. Juane defied the reassignment and continued to occupy the Tondo premises. On 10 May 2002, the Highest Consistory of Elders, upon recommendation and in accordance with church discipline, approved Juane’s expulsion as a pastor for defiance and rebellion, permanently extinguishing any right or authority to occupy church property.

• Demand to Vacate and Refusal: By letter dated 23 May 2002, the Highest Consistory of Elders, through the Secretary and Bishop Lazaro, demanded that Juane vacate and turn over all church property, including the cathedral, pastoral house, school, and premises. Juane received the demand but failed and refused to vacate. The complaint was filed on 17 September 2002, well within one year from the demand.

• Juane’s Defense on Corporate Personality: In the main case on the merits, Juane contended that IEMELIF’s transformation from a corporation sole to a corporation aggregate was legally defective, rendering IEMELIF without personality to eject him. He claimed to be the true corporation sole entitled to ownership and possession of the subject property, and he had filed a separate action for reconveyance (Civil Case No. 03-018777) before the RTC of Manila. The RTC had already decided that case against Juane, a ruling affirmed by the Court of Appeals and then pending review before the Supreme Court.

• Lack of Personality to Sue: Juane contended that the “IEMELIF” that filed the complaint had no personality to eject him because the church’s transformation from a corporation sole to a corporation aggregate was legally defective. The church remained a corporation sole, and he, as the surviving corporation sole, was the lawful owner entitled to physical possession of the property.

• Jurisdiction: Whether the complaint for unlawful detainer filed by IEMELIF constituted an intra-corporate dispute beyond the jurisdiction of the Metropolitan Trial Court.

• Corporate Personality and Right to Eject: Whether the alleged defective transformation of IEMELIF from a corporation sole to a corporation aggregate deprived IEMELIF of personality to eject Juane, and whether the question of ownership could be raised as a defense in the ejectment suit.

• Jurisdiction: The MeTC properly exercised jurisdiction. Jurisdiction over the subject matter is determined by the allegations of the complaint, and the complaint’s averments—not the defenses set up in a motion to dismiss—are controlling. The complaint in Civil Case No. 173711-CV sufficiently stated all the jurisdictional elements of an unlawful detainer action: (1) IEMELIF was the registered owner from whom possession was withheld; (2) Juane was the person unlawfully withholding possession after the expiration of his authority to occupy by virtue of his appointment as Resident Pastor; (3) a demand to vacate was made on 23 May 2002; and (4) the action was commenced on 17 September 2002, within one year from the demand. The invalidity of Juane’s removal and reassignment was a defense first raised in the motion to dismiss, which cannot be considered for purposes of ascertaining jurisdiction. Because the complaint did not seek to litigate the validity of the corporate acts of removal or reassignment, no intra-corporate controversy was properly presented. The ruling in Magay v. Estiandan that jurisdiction cannot be made to depend upon the defendant’s defenses squarely applied.

• Corporate Personality and Right to Eject: Even assuming, arguendo, that IEMELIF’s transformation from a corporation sole to a corporation aggregate was legally defective, the governing head remained unchanged. A corporation sole consists of a single member—the chief archbishop, bishop, priest, minister, or other presiding elder. If the transformation to a corporation aggregate did not materialize, the corporation sole would still be Bishop Lazaro, who himself performed the acts of removing Juane as Resident Pastor of the Tondo Congregation. If the transformation did materialize, the corporation aggregate was composed of the Highest Consistory of Elders, which approved the very same acts. In either scenario, the same authority that appointed Juane possessed the power to remove or transfer him. Juane’s claim of ownership over the subject property was not a valid defense in an ejectment case. An action for reconveyance (accion reivindicatoria) can coexist with an ejectment suit involving the same property because the only issue in an unlawful detainer action is physical or material possession, independent of any claim of ownership. Ownership may be examined only provisionally to determine who is entitled to possession de facto. The trial court’s factual finding that IEMELIF sufficiently proved its allegations was affirmed by the Court of Appeals and was binding on the Supreme Court, which is not a trier of facts.

• Jurisdiction Determined by Allegations of the Complaint — The nature of an action and the court that has jurisdiction over it are determined exclusively by the material allegations of the complaint, irrespective of whether the plaintiff is entitled to recover upon all or some of the claims. Defenses asserted in an answer or a motion to dismiss cannot be considered in resolving the issue of jurisdiction; otherwise, jurisdiction could depend almost entirely upon the defendant. (Citing Magay v. Estiandan and Abrin v. Campos.)

• Elements of Unlawful Detainer — For the metropolitan trial court to acquire jurisdiction over an unlawful detainer case, the complaint must allege: (1) the plaintiff is a vendor, vendee, or other person from whom possession of any land or building is unlawfully withheld after the expiration or termination of the right to hold possession by virtue of any contract, express or implied; (2) the defendant is the person unlawfully withholding possession after the expiration or termination of that right; (3) a demand to comply with the contract or vacate the premises was made; and (4) the action is commenced within one year from the last demand. (Rule 70, Sections 1–2, Rules of Court.)

• Physical Possession as Sole Issue in Ejectment — The only issue to be resolved in an unlawful detainer case is physical or material possession of the property involved, independent of any claim of ownership by any of the parties. Ejectment cases are designed to summarily restore physical possession to one illegally deprived thereof, without prejudice to the settlement of opposing claims of juridical possession in a separate appropriate proceeding. The question of ownership may only be provisionally ruled upon for the sole purpose of determining who is entitled to possession de facto. An action for reconveyance (accion reivindicatoria) has no effect on and can exist concurrently with an ejectment case involving the same property.

• Corporation Sole: Identity of Governing Head — Under Section 110 of the Corporation Code, a corporation sole consists of a single member—the chief archbishop, bishop, priest, minister, rabbi, or other presiding elder—formed to administer the affairs, properties, and temporalities of a religious denomination. Where a purported transformation from a corporation sole to a corporation aggregate is legally defective, the corporation sole continues in the person of the same presiding elder, whose acts are valid. The authority to appoint carries with it the correlative power to remove or reassign.

• “Jurisdiction over the subject matter is determined by the allegations of the complaint, irrespective of whether or not the Plaintiff is entitled to recover upon all or some of the claims asserted therein – a matter that can be resolved only after and as a result of the trial. Nor may the jurisdiction of the court be made to depend upon the defenses set up in the answer or upon the motion to dismiss, for, were we to be governed by such rule, the question of jurisdiction could depend almost entirely upon the defendant.”

• “The jurisdictional elements needed to be alleged in a Complaint for unlawful detainer are the following: (1) the plaintiff is a vendor, vendee, or other person from whom possession of any land or building is unlawfully withheld after the expiration or termination of the right to hold possession, by virtue of any contract, express or implied; (2) the defendant is the person unlawfully withholding the same from the plaintiff after the expiration or termination of the right to hold possession, by virtue of any contract express or implied; (3) the plaintiff issued a demand for the defendant to comply with the contract or vacate the said premises; and (4) the action is commenced within one year from the demand.”

• “An action for reconveyance or accion reivindicatoria has no effect and can exist at the same time as ejectment cases involving the same property. This is because the only issue to be resolved in an unlawful detainer case is physical or material possession of the property involved, independent of any claim of ownership by any of the parties involved.”

• “Even if the transformation of IEMELIF from a corporation sole to a corporation aggregate was legally defective, its head or governing body, i.e., Bishop Lazaro, whose acts were approved by the Highest Consistory of Elders, still did not change.”

• Magay v. Estiandan, G.R. No. L-28975, 69 SCRA 456 (1976) — Followed as controlling; affirmed the rule that jurisdiction is determined by the allegations of the complaint, not by defenses set up in the answer or motion to dismiss.

• Abrin v. Campos, G.R. No. 52740, 203 SCRA 420 (1991) — Followed; reiterated that the nature of the action and the court’s jurisdiction are determined by the plaintiff’s allegations.

• Co v. Militar, 466 Phil. 217 (2004) — Cited for the principle that the only issue in an ejectment case is physical or material possession, independent of any claim of ownership.

• Barnes v. Padilla, G.R. No. 160753, 461 SCRA 533 (2005) — Cited for the summary nature of ejectment proceedings, designed to restore physical possession without prejudice to the settlement of juridical possession.

• Umpoc v. Mercado, G.R. No. 158166, 449 SCRA 220 (2005) — Cited for the rule that ownership may be provisionally ruled upon solely to determine possession de facto.

• Del Rosario v. Jimenez, 118 Phil. 565 (1963); Guzman v. Court of Appeals, G.R. No. 81949, 177 SCRA 604 (1989); Sy v. Court of Appeals, G.R. No. 95818, 200 SCRA 117 (1991) — Cited to support that an action for reconveyance can coexist with an ejectment case.

• Section 110, Corporation Code — Defines a corporation sole as one formed by the chief archbishop, bishop, priest, minister, rabbi, or other presiding elder of a religious denomination for the purpose of administering the affairs, properties, and temporalities of such denomination. The provision was applied to establish that whether IEMELIF remained a corporation sole or became a corporation aggregate, the same governing head (Bishop Lazaro) exercised authority over the property and personnel, thus sustaining the validity of the reassignment and expulsion.

• Rule 70, Sections 1–2, Rules of Court — Prescribes the jurisdictional requirements for an unlawful detainer action. The complaint’s recital of all elements—ownership/entitlement to possession, termination of the right to occupy, demand to vacate, and filing within one year—brought the case squarely within the MeTC’s original jurisdiction.

All members of the Third Division concurred: Consuelo Ynares-Santiago (Chairperson), Presbitero J. Velasco, Jr., Antonio Eduardo B. Nachura, and Diosdado M. Peralta.