G.R. No. L-9582, December 24, 1914
IRENE CALAMPIANO, plaintiff-appellant, vs. EULALIO TOLENTINO, defendant-appellee.

FACTS:
The plaintiff, Irene Calampiano, filed an action for ejectment and damages for illegal detention in the Court of First Instance (CFI) of Tayabas. Due to a heavy caseload and the unavailability of court sessions in the province for several months, the CFI, pursuant to Section 3 of Act No. 2041, assigned the justice of the peace of the provincial capital to take cognizance and try the case. During trial, the plaintiff objected to the jurisdiction of the justice of the peace, arguing that Act No. 2041 was unconstitutional, that the CFI exceeded its authority in making the assignment, and that the justice of the peace lacked jurisdiction to hear the case. The justice of the peace overruled the objection and ordered the trial to proceed. The plaintiff refused to participate further, leading to the dismissal of her action. She appealed the dismissal order.

ISSUE:
Whether a justice of the peace, assigned by a Court of First Instance under Act No. 2041 to try a case involving title to real property, has jurisdiction to hear and determine such case.

RULING:
The Supreme Court affirmed the dismissal of the action. It held that under Act No. 2041, a justice of the peace assigned by the CFI to try certain cases acts as a judge of the Court of First Instance for that specific case, not as a justice of the peace. The statute temporarily confers upon the justice of the peace all powers and authority of a CFI judge to hear and determine cases originally cognizable by the CFI, provided the value of the subject matter does not exceed two thousand pesos (excluding interest and costs) and the case does not involve tax legality or admiralty jurisdiction. This assignment does not deprive the CFI of its jurisdiction under the Philippine Bill; rather, it temporarily increases the number of CFI judges. The Court distinguished this case from Barrameda v. Moir (25 Phil. 44), which invalidated statutes conferring exclusive jurisdiction on justices of the peace over real estate actions, as Act No. 2041 does not divest the CFI of jurisdiction but authorizes a justice of the peace to exercise CFI powers in a delegated capacity. Thus, the justice of the peace had valid jurisdiction to try the case, including issues involving title to real property.