G.R. No. L-11716; April 30, 1959
ENCARNACION BACANI, petitioner, vs. HON. HIGINIO B. MACADAEG, as Judge of the Court of First Instance of Manila, AND THE SHERIFF OF MANILA, respondents.

FACTS

Petitioner Encarnacion Bacani was the owner of a parcel of land with a house in Manila. On May 16, 1949, she mortgaged the property to respondent Rehabilitation Finance Corporation (RFC) to secure a loan. Due to her failure to comply with the mortgage terms, RFC foreclosed the property. At a public auction on September 10, 1951, RFC purchased the property, subject to Bacani’s right of redemption within one year. Bacani continued to occupy the premises. After she failed to redeem the property, RFC consolidated its ownership on April 15, 1953.
Prior to the consolidation, on August 29, 1952, Bacani offered to repurchase the property from RFC under specified conditions, including a 20% down payment to be completed within two months from notice of acceptance, with failure resulting in automatic cancellation of the sale and forfeiture of her deposit as rent/damages. RFC accepted her offer on September 15, 1952, with a reduced repurchase price. Bacani failed to complete the 20% down payment within the stipulated period. Despite several extensions and partial payments, she only paid a total of P1,500, leaving a balance. On January 18, 1955, RFC notified Bacani that the resale contract was cancelled due to her failure, demanded payment of unpaid rentals, and required her to vacate the premises.
RFC filed a detainer complaint against Bacani in the Municipal Court of Manila. Bacani filed an answer and a supplemental answer, raising the issue of ownership. She also filed a motion to dismiss for lack of jurisdiction, which was denied. The Municipal Court rendered judgment ordering Bacani to vacate, pay arrears in rentals, and pay monthly rentals until vacating. Bacani appealed to the Court of First Instance (CFI). RFC moved for execution of the Municipal Court’s judgment pending appeal due to Bacani’s failure to file a supersedeas bond and pay monthly rentals. The CFI granted the motion and issued a writ of execution.
Bacani filed the present petition for certiorari and prohibition, claiming the Municipal Court had no jurisdiction because the issue of ownership was raised, rendering its judgment and the subsequent CFI orders and writ of execution null and void. This Court initially issued a preliminary injunction and later a preliminary mandatory injunction. Notably, on December 18, 1956 (the day this petition was filed), Bacani wrote to RFC requesting postponement of the ejectment’s enforcement until December 30, 1956, promising to surrender peaceful possession by that date.

ISSUE

Whether the Municipal Court (and subsequently the CFI) lacked jurisdiction over the detainer case because the petitioner raised the issue of ownership or title to the property.

RULING

The petition is denied. The Municipal Court retained jurisdiction over the detainer case.
The Supreme Court ruled that the mere filing of an answer claiming title or raising the question of ownership does not divest an inferior court (like the Municipal Court) of its jurisdiction over forcible entry and detainer cases. The Court found it clear that ownership of the property had never been transferred back to Bacani and remained with RFC. By continuing to stay on the premises after the foreclosure sale and RFC’s consolidation of ownership, Bacani merely acquired the status of a lessee. Her own offer to repurchase stipulated that failure to complete the down payment would result in automatic cancellation of the sale, with her deposit applied as rent. Therefore, she could not defeat RFC’s title, and the contract to resell was considered automatically cancelled.
Furthermore, the Court noted that Bacani’s letter of December 18, 1956, requesting a postponement to vacate and promising to surrender possession, rendered her unworthy of the equitable relief sought in the proceedings. The writ of preliminary mandatory injunction was dissolved, with costs against the petitioner.