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

Avanceña, C.J.

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 period ending in May 1923, failed to pay the agreed rent, and refused to return possession after the lease expired. The contract of lease was attached to the complaint. The defendant, in his answer, generally denied the allegations and claimed the lease (and a related pacto de retro sale) was simulated and that the true transaction was a mortgage. He did not specifically deny under oath the genuineness and due execution of the lease contract. The justice of the peace court decided on the merits. On appeal to the Court of First Instance (CFI), the defendant moved to dismiss for lack of jurisdiction, arguing the justice of the peace court had no original jurisdiction. The CFI denied the motion, received evidence, but ultimately held that the justice of the peace court lacked jurisdiction because the case involved a question of title. It quashed the lower court’s judgment and declared itself without appellate jurisdiction, while reserving the parties’ right to file the proper action. The plaintiffs appealed this CFI judgment.

ISSUE

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

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 case was remanded to the CFI for trial on the merits.

The Court ruled that the action, as pleaded in the complaint, was a clear case of unlawful detainer under Section 80 of the Code of Civil Procedure. The plaintiffs’ cause of action was based solely on the expiration of the lease term and the defendant’s refusal to vacate. The question of ownership was not essential to resolve the issue of possession in this summary proceeding. The purpose of the detainer action is to provide a speedy remedy to protect actual possession or a right to possession derived from a contract, without delving into title.

The defendant’s claim that the lease was simulated and that the real transaction was a mortgage raised a collateral issue not necessary for the resolution of the detainer case. Furthermore, by failing to specifically deny under oath the genuineness and due execution of the lease contract (as copied in the complaint), the defendant was deemed to have admitted its execution. The Court distinguished this case from prior rulings where jurisdiction was denied, noting that here the action was based purely on a contract of lease unrelated to any other contemporaneous agreement, unlike cases where the lease was inextricably linked to a pacto de retro sale in the same instrument. The exception in Act No. 1627 , which deprives justices of the peace of jurisdiction when a question of title is involved, applies only when ownership is so necessarily intertwined that possession cannot be decided without settling title. It does not apply simply because the defendant raises the question of ownership.