G.R. No. L-10354; March 17, 1916

FACTS:
On February 3, 1902, plaintiffs-appellants Felipe Dorado and Antonia Vista sold three parcels of coconut land to defendants-appellants Agripino Viriña and Petra Cuento under a pacto de retro (sale with right of repurchase) for P100, with no stipulated redemption period. The parties agreed that the vendors (Dorado and Vista) would remain in possession as lessees, paying a quarterly rent of P15, with the purchasers having the right to take possession if the rent was not paid.

On September 9, 1904, Agripino Viriña filed an action for forcible entry and detainer (unlawful detainer) against Felipe Dorado in the justice of the peace court of Nagcarlan, Laguna, presided over by defendant Vivencio Zulaibar. Viriña sought to recover nine months of unpaid rent and to eject Dorado. Dorado admitted the debt at the hearing. The court rendered judgment in favor of Viriña, ordering Dorado’s ejectment. The judgment was executed on October 11, 1904, and Viriña took possession.

On June 10, 1913, Dorado and Vista filed a complaint in the Court of First Instance of Laguna against the Viriña spouses and ex-justice Zulaibar. They sought: (1) annulment of the detainer proceedings and judgment, alleging lack of jurisdiction because no prior demand for rent was made and because the action was filed more than one year after the cause of action arose; (2) restitution of the land; and (3) damages for the Viriñas’ alleged bad faith possession and for Zulaibar’s alleged conspiracy.

The trial court partially granted the complaint. It declared the detainer proceedings null and void, held the Viriñas’ possession from 1904 to 1906 as in bad faith, and ordered them to pay P1,666 for fruits collected. However, it denied restitution of the land to Dorado and Vista and absolved Zulaibar. Both parties appealed.

ISSUE:
1. Whether the justice of the peace court had jurisdiction over the detainer action filed by Viriña against Dorado.

RULING:

DISPOSITIVE PORTION:
The Supreme Court MODIFIED the trial court’s judgment. It affirmed the absolution of all defendants (Agripino Viriña, Petra Cuento, and Vivencio Zulaibar) from the complaint and reversed the portions ordering the Viriñas to pay for fruits and declaring their possession in bad faith. The defendants were not obliged to restore the land to the plaintiffs. No costs were awarded.