G.R. No. 9489; September 11, 1915
PRUDENCIO CHICOTE, plaintiff-appellant, vs. LICERIO ACASIO, defendant-appellee.

FACTS:
Prudencio Chicote filed a complaint in the justice of the peace court of Davao against Licerio Acasio, alleging that Acasio had deprived him of possession of a parcel of land. Chicote prayed that Acasio be ordered to vacate the land. The justice of the peace rendered judgment, holding that Acasio had not usurped the land from Chicote and that the land belonged to Acasio until proven otherwise, and thus there was no legal basis to eject Acasio. Chicote appealed to the Court of First Instance (CFI) of Davao, which affirmed the judgment. Chicote then moved to annul all proceedings, arguing that the justice of the peace lacked jurisdiction because Act No. 1627 prohibited justices of the peace from trying cases involving titles to land. The CFI denied the motion, ruling that the action was for recovery of possession, not for determination of title. Chicote appealed this ruling to the Supreme Court.

ISSUE:
Whether the justice of the peace court had jurisdiction over the case, considering that the complaint was for recovery of possession and the judgment made incidental references to ownership.

RULING:
The Supreme Court affirmed the order of the CFI, holding that the justice of the peace had jurisdiction. The Court ruled that the action filed by Chicote was one for recovery of possession (detainer), not an action to determine title. While the justice of the peace received evidence on the question of title and made observations thereon, this was permissible under Section 68 of Act No. 136, as amended, which allows a justice of the peace in forcible entry and detainer proceedings to receive evidence on title solely for the purpose of determining the character and extent of possession and the damages for detention. The finding in the judgment that the land belonged to Acasio was merely incidental to the primary finding that there was no usurpation and no legal basis for ejectment. It did not convert the action into one for determination of ownership. Therefore, the proceedings were valid, and the CFI correctly denied the motion for annulment. The appeal was dismissed, and costs were imposed on the appellant.