GR 43550; (November, 1936) (Digest)
G.R. No. 43550 ; November 27, 1936
SEGUNDO MONTEBLANCO, plaintiff, vs. THE HINIGARAN SUGAR PLANTATION, INC., and AGUSTIN CORUÑA, defendants. PHILIPPINE NATIONAL BANK, CELSO S. GUANCO, as administrator of the intestate estate of Espiridion Guanco, and NICETAS SIGUENZA, intervenors. NICETAS SIGUENZA, appellant. PHILIPPINE NATIONAL BANK, appellee.
FACTS
The case originated as an action for forcible entry and detainer filed by Segundo Monteblanco in the justice of the peace court of Hinigaran in September 1924. The Philippine National Bank intervened. The justice of the peace court initially forwarded the case to the Court of First Instance (CFI), believing it lacked jurisdiction. The CFI remanded it back, ruling it was a forcible entry case within the exclusive original jurisdiction of the justice of the peace court. The case was received back by the justice of the peace court on June 15, 1925. No action was taken for over eight years until November 1933, when a hearing was set and a decision was rendered in December 1933. The Philippine National Bank appealed to the CFI and moved to dismiss, arguing the justice of the peace lost jurisdiction. The CFI granted the motion, declared the judgment null and void, and dismissed the complaint and interventions. Intervenor Nicetas Siguenza appealed.
ISSUE
Whether the justice of the peace court retained jurisdiction to decide the forcible entry and detainer case after an inaction of over eight years from the time it was remanded for trial.
RULING
No. The Supreme Court affirmed the CFI’s dismissal, but on different grounds. It held that while Section 64 of Act No. 190 (on adjournments) did not deprive the court of jurisdiction merely because three months lapsed, the justice of the peace court lost jurisdiction due to the parties’ and the court’s extreme inaction and neglect. Forcible entry and detainer cases are designed for speedy resolution. The court’s jurisdiction is limited to one year from the accrual of the cause of action. Here, the case was effectively abandoned for over eight years after remand. By the time the court revived it in 1933, it had long lost jurisdiction, which could not be restored. The Supreme Court affirmed the order based on the doctrine of laches and loss of jurisdiction due to inordinate delay, not on the CFI’s interpretation of Section 64.
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