G.R. No. 171219 Case Digest

G.R. No. 171219, September 3, 2012

Atty. Fe Palmiano-Salvador

vs Constantino angeles, respondents

Ponente: Peralta

Facts:

This is a petition to reversed and set aside the decision of the CA dismissing the petition before them.

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 (respondent’s 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.