G.R. No. L-7257 and L-7258; October 8, 1913
LEONARDO LUCIDO and ROMAN LUCIDO, plaintiffs-appellees, vs. ROMUALDO VITA, defendant-appellant.

FACTS:
Two separate actions were filed by the plaintiffs-appellees, Leonardo and Roman Lucido, against the defendant-appellant, Romualdo Vita, in the justice of the peace court of Nagcarlan, Laguna.
1. G.R. No. L-7257: An action for forcible entry and detainer (unlawful detainer). The plaintiffs alleged they were owners of nine parcels of land which the defendant had leased since 1892. They sought to eject the defendant for non-payment of rent, specifically for failing to pay: (a) P400 as promised in a 1904 compromise agreement; (b) rent from January 5, 1904, to January 5, 1910 (P581.28); and (c) future rent/damages from January 5, 1910, until restitution.
2. G.R. No. L-7258: An action to recover a sum of money for the use and occupation of the same lands, covering the period from January 5, 1892, to January 5, 1904.

In both cases, the defendant demurred to the complaints in the justice of the peace court. The justice of the peace sustained the demurrers and rendered judgment in favor of the defendant. The plaintiffs appealed both cases to the Court of First Instance (CFI) of Laguna.

In the CFI, the plaintiffs filed the same complaints that were the basis of the actions in the justice of the peace court. The defendant again demurred. The CFI overruled the demurrers. When the defendant failed to answer within the prescribed time, the CFI, upon motion of the plaintiffs, rendered judgment in their favor in both cases based on the allegations of the complaints. The defendant appealed these CFI judgments to the Supreme Court.

ISSUE:
Did the Court of First Instance have jurisdiction to try and decide the cases on their merits upon appeal from the justice of the peace court, where the justice of the peace had rendered judgment on a demurrer without a trial on the facts?

RULING:
No. The Supreme Court annulled the judgments of the Court of First Instance and ordered the cases remanded to the justice of the peace court for trial.

The Court held that the jurisdiction of the CFI on appeal from a justice of the peace court is purely appellate. When an appeal is taken from a judgment rendered by a justice of the peace on a demurrer (a question of law alone), without any trial on the merits or issues of fact, the CFI’s power is limited to reviewing that ruling on the law. It cannot try the case on its merits as if it were a court of original jurisdiction.

In these cases, since the justice of the peace sustained the demurrers and dismissed the complaints without any trial of the facts, there were no issues of fact to retry on appeal. The CFI’s proper course of action was to review the correctness of the justice of the peace’s ruling on the demurrer. If the CFI found the demurrer was erroneously sustained, it should have reversed the judgment and remanded the case to the justice of the peace court with instructions to overrule the demurrer and proceed to trial on the merits.

By overruling the demurrer itself and then proceeding to render judgment on the merits based on the unanswered complaints, the CFI exercised original jurisdiction, which it did not possess in the matter. Therefore, its judgments were rendered without jurisdiction and were null and void. The cases must be returned to the justice of the peace court for a proper trial.