G.R. No. L-57645 February 27, 1987
Eusebio Bernabe and Teresita P. Bernabe, petitioners, vs. Hon. Artemon D. Luna, Presiding Judge, Branch XXXII, Court of First Instance of Manila and Jesus Gacuya, respondents.

FACTS

Petitioners Eusebio and Teresita Bernabe filed a complaint for “Recovery of Possession” with the Court of First Instance (CFI) of Manila against respondent Jesus Gacuya. They alleged ownership of a lot in Tondo, Manila, upon which Gacuya had constructed a house without their permission. They made a written demand on November 14, 1980, for him to remove the house and pay damages, which he refused. The CFI dismissed the complaint, ruling it was an ejectment case within the exclusive jurisdiction of the City Court. The court held that Gacuya’s unlawful withholding of possession commenced only from the receipt of the demand letter, and since the complaint was filed on February 19, 1981, the one-year period for filing an ejectment suit had not lapsed.
Petitioners moved for reconsideration, arguing there was never a lessor-lessee relationship between them and Gacuya. They contended that Gacuya was originally a lessee of the former owner, Fejosera Investment, Inc., but when they bought the lot on December 17, 1973, that lease was automatically extinguished. Thus, Gacuya’s possession became illegal from 1973, making their action an accion publiciana (for possession lasting over one year) within the CFI’s jurisdiction. The motion was denied, prompting this certiorari petition.

ISSUE

Whether the respondent Court of First Instance correctly dismissed the complaint for lack of jurisdiction, ruling that the action was for unlawful detainer (ejectment) falling within the exclusive original jurisdiction of the City Court.

RULING

The Supreme Court dismissed the petition, upholding the CFI’s dismissal. The legal logic centers on the nature of the action and the commencement of the cause of action for unlawful detainer. The Court clarified that while petitioners purchased the lot in 1973, Gacuya’s original lease from Fejosera Investment, though unrecorded, was known to the petitioners, who allowed it to continue without immediate action. Under Article 1676 of the Civil Code, a purchaser who knows of an existing lease cannot arbitrarily terminate it without a demand. The lease, having no fixed period, was terminable at the will of the petitioners, but such termination required a positive act.
The Court ruled that the demand letter of November 14, 1980, constituted the requisite act of termination. Consequently, Gacuya’s possession became unlawful only from that date, not from the 1973 sale. An action for unlawful detainer must be filed within one year from the date of last demand. Since the complaint was filed on February 19, 1981, well within the one-year period, the case was correctly characterized as unlawful detainer. Jurisdiction over unlawful detainer cases was vested exclusively in the City Court (now Metropolitan Trial Court), not the CFI (now Regional Trial Court). Therefore, the CFI properly dismissed the complaint for lack of jurisdiction.