GR 44198; (May, 1938) (Digest)
G.R. No. 44198; May 31, 1938
MANUEL B. CALUPITAN, plaintiff-appellant, vs. CONSUELO B. AGLAHI, ET AL., defendants. CONSUELO B. AGLAHI, appellee.
FACTS
Manuel B. Calupitan filed an action for illegal detainer in the justice of the peace court of Santa Cruz, Laguna, seeking to eject the spouses Monico Aglahi and Consuelo Bernardino de Aglahi from a property. The justice of the peace court ruled in favor of Calupitan, ordering the defendants to vacate. In its decision, the court determined that the property was conjugal property of the defendants, not the paraphernal property of the wife, and based its ejectment order on that finding. On appeal to the Court of First Instance (CFI) of Laguna, the defendant Consuelo Aglahi moved for dismissal on the ground that the justice of the peace court acted in excess of its jurisdiction by deciding the question of ownership. The CFI granted the motion and dismissed the case.
ISSUE
Whether the Court of First Instance erred in dismissing the case on the ground that the justice of the peace court acted in excess of its jurisdiction in determining the title to the property in the illegal detainer proceedings.
RULING
No, the CFI did not err. The Supreme Court affirmed the order of dismissal. Under Section 68 of Act No. 136 (as amended), a justice of the peace court, in forcible entry and detainer proceedings, has original jurisdiction but may receive evidence on the question of title solely for the purpose of determining the character and extent of possession and damages for detention. It does not have jurisdiction to determine who is the owner or the extent of the title. In this case, the justice of the peace court exceeded its jurisdiction when it ruled on whether the property was conjugal or paraphernal, as this was a determination of title. Consequently, its decision was null and void. Since the determination of title was necessary for the ejectment decision, the justice of the peace court lacked original jurisdiction. On appeal, the CFI therefore had no jurisdiction to decide the merits and correctly dismissed the case.
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