GR L 9540; (April, 1957) (Digest)
G.R. No. L-9540; April 30, 1957
SEVERINO MANOTOK, plaintiff-appellee, vs. ELADIO GUINTO, defendant-appellant.
FACTS
The plaintiff-appellee, Severino Manotok, filed a complaint for ejectment (unlawful detainer) against the defendant-appellant, Eladio Guinto, in the Municipal Court of Manila. The Municipal Court ruled in favor of Manotok. Guinto appealed to the Court of First Instance of Manila, arguing that the Municipal Court lacked jurisdiction because the complaint was filed more than one year after the initial demand to vacate. The parties agreed to submit the case for decision on the pleadings. The Court of First Instance found that Manotok owned the land occupied by Guinto on an agreed monthly rental of P6.25, which was an increase from the previous rent due to increased land taxes. Guinto refused to pay the increased rental. The court upheld Manotok’s right to eject Guinto and ordered Guinto to pay the increased rental effective April 1953. Guinto appealed directly to the Supreme Court.
ISSUE
Whether or not the Municipal Court (the court of origin) had jurisdiction over the ejectment case, specifically, whether the complaint was filed within the one-year period prescribed for summary actions of unlawful detainer.
RULING
The Supreme Court affirmed the judgment of the Court of First Instance, holding that the Municipal Court had jurisdiction. The Court ruled that the one-year period for filing an unlawful detainer action commenced from the demand to vacate made on July 12, 1954, not from the notice given in March 1953 which presented an alternative to pay an increased rental or vacate. The March 1953 notice was not the demand contemplated by the Rules of Court for unlawful detainer based on failure to pay rent or comply with lease conditions. When Guinto elected to stay after the March 1953 notice, he assumed the obligation to pay the new rental. His default in that obligation and a subsequent demand to vacate were necessary before an ejectment action could accrue. Since the demand to vacate was made on July 12, 1954, and the complaint was filed on August 27, 1954, the action was filed within the one-year period and was within the Municipal Court’s jurisdiction. Costs were awarded against the appellant.