G.R. No. 26786 , December 31, 1927
Catalino Sevilla, et al. vs. Gaudencio Tolentino

FACTS

The plaintiffs, Catalino Sevilla and others, filed an action in the justice of the peace court to recover possession of two parcels of land from the defendant, Gaudencio Tolentino. They alleged that the defendant leased the land from them for a two-year term ending in May 1923, failed to pay the agreed rent, and refused to return the property after the lease expired. The defendant, in his answer, denied the material allegations and claimed that the lease contract (and a related pacto de retro sale) was simulated and that the true transaction was a simple mortgage. He did not, however, specifically deny under oath the genuineness and due execution of the lease contract attached to the complaint. The justice of the peace court decided on the merits, and the defendant appealed to the Court of First Instance (CFI). Before the CFI hearing, the defendant moved to dismiss for lack of jurisdiction, arguing that the justice of the peace court had no original jurisdiction because the case involved a question of title. The CFI denied the motion, received evidence, but ultimately held that the justice of the peace court lacked jurisdiction and dismissed the case, reserving the parties’ right to file the proper action. The plaintiffs appealed this dismissal.

ISSUE

Whether the justice of the peace court had original jurisdiction over the action for unlawful detainer based on the expiration of a lease, notwithstanding the defendant’s claim that the lease was simulated and that the real transaction was a mortgage involving a question of ownership.

RULING

YES. The Supreme Court reversed the CFI’s judgment and held that the justice of the peace court had original jurisdiction, and consequently, the CFI had appellate jurisdiction to decide the case on its merits.

The Court ruled that the action, as pleaded in the complaint, was a straightforward unlawful detainer case under Section 80 of the Code of Civil Procedure. The plaintiffs’ cause of action rested solely on two facts: (1) the existence of a contract of lease, and (2) the expiration of its term. The defendant’s failure to specifically deny under oath the genuineness of the written lease contract constituted an implied admission of its execution.

The summary action for forcible entry and detainer is designed to protect actual possession and provide an expeditious remedy. The exception under Section 3 of Act No. 1627 , which strips the justice of the peace of jurisdiction when a question of title is involved, must be strictly construed. It applies only when the question of ownership is so necessarily intertwined that it is impossible to decide possession without first settling ownership. It does not apply simply because the defendant raises the question of ownership.

In this case, the defendant’s claim of simulation and mortgage did not necessarily involve a question of title that had to be resolved to decide the possession issue. The plaintiffs were not required to prove ownership, and the defendant could not properly deny it in this summary proceeding. The only relevant issues were the lease and its expiration. The Court distinguished this case from prior rulings where the action for possession was directly derived from a resolved question of ownership (like an expired pacto de retro sale). The record was remanded to the CFI for a decision on the merits.