G.R. No. L-45123; April 12, 1939
AGRIPINO INFANTE, plaintiff-appellant, vs. MARCOS DULAY, defendant-appellee.

FACTS

Agripino Infante filed a complaint for unlawful detainer in the justice of the peace court of Laoang, Samar, against Marcos Dulay, seeking to recover possession of a parcel of land. The justice of the peace court ruled in favor of Infante, ordering Dulay to vacate the land and pay damages. Dulay appealed to the Court of First Instance (CFI) of Samar. After trial, the CFI dismissed the case, holding that the justice of the peace court lacked original jurisdiction because the evidence showed Dulay did not employ force, intimidation, threat, strategy, or stealth to gain possession—the grounds required for an unlawful detainer action. Infante appealed to the Supreme Court.

ISSUE

Whether the justice of the peace court had jurisdiction to originally take cognizance of the unlawful detainer case.

RULING

Yes. The Supreme Court held that the jurisdiction of a justice of the peace court (now municipal court) over unlawful detainer cases is conferred by law upon the timely filing of a complaint that alleges facts constitutive of forcible entry or unlawful detainer. The court’s jurisdiction is determined by the allegations in the complaint, not by the ultimate proof of those facts during trial. Since Infante’s complaint properly alleged such facts, the justice of the peace court validly exercised its original jurisdiction. The CFI, on appeal, acquired appellate jurisdiction and should have decided the case on its merits based on the evidence, not dismissed it for lack of jurisdiction. The Supreme Court modified the CFI’s judgment, stating the dismissal was for lack of merit, not lack of jurisdiction.

AI Generated by Armztrong.