REMEDIAL LAW REVIEW CASE DIGEST

TOPIC Jurisdiction of Parties

CASE TITLE ATTY. FE Q. PALMIANO-SALVADOR v. CONSTANTINO ANGELES
GR NO. 171219 DATE: September 3, 2012
DOCTRINE
Courts acquire jurisdiction over the plaintiffs upon the filing of the complaint, and to be bound by a decision,
a party should first be subjected to the court's jurisdiction.
FACTS
Respondent Angles is the registered owner of a parcel of land in Sampaloc, Manila. Jelly Galiga, the lessee
of the said property, represented himself as the owner and sold the same to Salvador. Due to Savlador’s
failure to heed to the demand to vacate, Angeles, through one Rosauro Diaz, filed a complaint for ejectment
before MeTC Manila. MeTC ruled in favor or Angeles.

In the appeal filed by Salvador, she alleged that DIAZ, who filed the complaint for ejectment, had no
authority whatsoever from respondent-appellee ANGELES at the time of filing of the suit. However, the
appeal was denied by the RTC and affirmed by CA.
ISSUE
Whether the MeTC has acquired jurisdiction over the parties despite the lack of proof of authority to file of
the complainant
HELD
NO. The complaint before the MeTC was filed in the name of respondent, but it was one Rosauro Diaz who
executed the verification and certification dated October 12, 1994, alleging therein that he was respondent's
attorney-in-fact. There was, however, no copy of any document attached to the complaint to prove Diaz's
allegation regarding the authority supposedly granted to him. Furthermore, the SPA subsequently presented
was issued more than a month after the complaint was filed.

What then, is the effect of a complaint filed by one who has not proven his authority to represent a plaintiff in
filing an action?

In Tamondong v. Court of Appeals, the Court categorically stated that "[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."

This ruling was reiterated in Cosco Philippines Shipping, Inc. v. Kemper Insurance Company, where the
Court went on to say that "[i]n order for the court to have authority to dispose of the case on the merits, it
must acquire jurisdiction over the subject matter and the parties. Courts acquire jurisdiction over the
plaintiffs upon the filing of the complaint, and to be bound by a decision, a party should first be
subjected to the court's jurisdiction. Clearly, since no valid complaint was ever filed with the [MeTC], the
same did not acquire jurisdiction over the person of respondent [plaintiff before the lower court]."

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.

NOTES

4C (2020 – 2021)