G.R. No. L-11638; April 30, 1959
APOLONIO PANER, petitioner-appellant, vs. GAVINO SEPULVEDA, Judge of the Municipal Court of Davao City, and GUILLERMO T. GARCIA, respondents-appellees.

FACTS

On June 23, 1956, Guillermo T. Garcia filed a detainer action in the Municipal Court of Davao City against Johnny Anthony and Crisostomo Paner to recover possession of a house (Civil Case No. 2253). On July 6, 1956, Apolonio Paner filed a motion to intervene, attaching his answer in intervention. The Municipal Court denied his motion on July 19, 1956, and a motion for reconsideration was denied on July 27, 1956. Subsequently, on July 31, 1956, Apolonio Paner filed a petition for mandamus in the Court of First Instance of Davao to compel the Municipal Court to allow his intervention. After the respondents filed their answers and a hearing was conducted, the Court of First Instance rendered judgment on September 26, 1956, dismissing the petition for mandamus. A motion for reconsideration was denied on October 6, 1956, prompting this appeal.
The background reveals that after a judgment became final and executory in a separate case (Civil Case No. 1213 of the Court of First Instance of Davao, Garcia vs. Mercado and Paner, et al.), a writ of execution was issued. Pursuant to this writ, the Sheriff of Davao levied upon execution and, on April 26, sold at public auction to Guillermo T. Garcia all of Apolonio Paner’s interests, rights, and title to a house located on Tiongko Avenue, Davao City, subject to Paner’s right of redemption within one year. Paner failed to redeem the house within the statutory period, leading the Sheriff to issue a certificate of absolute sale in favor of Garcia. In his answer in intervention attached to the motion in the detainer case, Paner impugned the validity of the execution sale, alleging lack of notice to him and failure to comply with court rules, and claimed he was still in possession of the house.

ISSUE

Whether the Municipal Court correctly denied Apolonio Paner’s motion to intervene in the detainer action.

RULING

The Supreme Court affirmed the judgment of the Court of First Instance dismissing the petition for mandamus. The Court held that if Apolonio Paner were allowed to intervene in the detainer action, he could raise questions challenging the validity of the execution sale and Garcia’s title to the house. Such questions pertain to issues of title over which the Municipal Court, in a detainer case, has no jurisdiction. Therefore, the Municipal Court was correct in denying the intervention to prevent the introduction of matters beyond its jurisdictional authority. Costs were imposed against the appellant.