Salvador vs. Angeles

A complaint filed by one who has not proven their authority to represent the plaintiff is not deemed filed and produces no legal effect, depriving the court of jurisdiction over the plaintiff.

Constantino Angeles was the registered owner of a parcel of land in Sampaloc, Manila, occupied by Jelly Galiga as a lessee from 1979 to 1993. In September 1993, Fe Salvador purchased the property from Galiga, who misrepresented himself as the owner. Salvador took possession of the property in November 1993. On November 18, 1993, Angeles demanded that Salvador vacate the premises, which she ignored.

• Ownership and Possession: Respondent Constantino Angeles was the registered owner of a parcel of land located at 1287 Castanos Street, Sampaloc, Manila, under Transfer Certificate of Title No. 150872. Jelly Galiga occupied the property as a lessee from 1979 to 1993.
• Alleged Sale: Petitioner Fe Salvador claimed she bought the property from Galiga on September 7, 1993, relying on his possession as an indication of ownership. Petitioner remained in possession from November 1993.
• Ejectment Complaint: On October 12, 1994, Rosauro Diaz filed a complaint for ejectment on behalf of respondent before the MeTC. Diaz executed the verification and certification, alleging he was respondent's attorney-in-fact, but no proof of authority was attached to the complaint.
• Belated and Defective SPA: Petitioner raised the issue of Diaz's lack of authority in her Answer and Position Paper. On December 11, 1995, respondent attached a Special Power of Attorney (SPA) to his Reply. However, the SPA was executed on November 16, 1994—over a month after the complaint was filed. Furthermore, the SPA was notarized by one Robert F. McGuire of Santa Clara County, California, but lacked the required certification from the Philippine Consulate General in San Francisco, California, rendering it devoid of evidentiary weight.

• Lack of Authority: Petitioner argued that Rosauro Diaz had no authority from respondent to file the ejectment complaint at the time of filing, as no special power of attorney was attached to the complaint.
• Nullity of Proceedings: Petitioner maintained that the failure to prove Diaz's authority at the time of filing was a jurisdictional defect, meaning the MeTC never acquired jurisdiction over the plaintiff and the complaint should be dismissed.

• Valid Sale by Lessee: Respondent countered that Galiga was a mere lessee and could not have validly transferred ownership to petitioner, justifying the ejectment.
• Subsequent Authority: Respondent impliedly relied on the subsequently executed SPA to validate Diaz's authority, notwithstanding its execution date and formal defects.

• Jurisdiction over the Plaintiff: Whether the failure of a representative to present proof of authority to represent the plaintiff at the time of filing the complaint deprives the court of jurisdiction over the plaintiff and renders the complaint a nullity.

• Jurisdiction over the Plaintiff: The complaint was deemed not filed, and the MeTC never acquired jurisdiction over the plaintiff. A complaint filed by an unauthorized representative produces no legal effect. Courts acquire jurisdiction over the plaintiff upon the valid filing of the complaint. Because Diaz lacked authority when the complaint was filed on October 12, 1994, and the SPA was executed only on November 16, 1994 (and was further defective for lacking consular certification), there was no valid complaint to confer jurisdiction. Consequently, all proceedings before the MeTC, RTC, and CA were null and void.

• Jurisdiction over the plaintiff upon filing of complaint — Courts acquire jurisdiction over the plaintiffs upon the filing of a valid complaint. To be bound by a decision, a party must first be subjected to the court's jurisdiction. If a complaint is filed by one not authorized to do so, the complaint is not deemed filed, and the court acquires no jurisdiction over the plaintiff. The court must dismiss the complaint for lack of jurisdiction.

• "If 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." — Citing Tamondong v. Court of Appeals, articulating the consequence of filing a complaint through an unauthorized representative.
• "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]." — Citing Cosco Philippines Shipping, Inc. v. Kemper Insurance Company, emphasizing that jurisdiction over the plaintiff is a prerequisite for the court to decide the case on the merits.

• Tamondong v. Court of Appeals, G.R. No. 158397, November 26, 2004, 444 SCRA 509 — Followed. Established the rule that a complaint filed by an unauthorized representative is not deemed filed and does not confer jurisdiction over the plaintiff.
• Cosco Philippines Shipping, Inc. v. Kemper Insurance Company, G.R. No. 179488, April 23, 2012 — Followed. Reiterated the doctrine that courts must acquire jurisdiction over the parties to dispose of the case on the merits, and a valid complaint is necessary to acquire jurisdiction over the plaintiff.

Presbitero J. Velasco, Jr., Roberto A. Abad, Jose Portugal Perez, Jose Catral Mendoza.