GR L 1555; (January, 1948) (Digest)
G.R. No. L-1555; January 31, 1948
GREGORIO NICOMEDES, petitioner-appellant, vs. RAMON A. YCASIANO ET AL., respondent-appellees.
FACTS
Petitioner Gregorio Nicomedes sought to declare the Municipal Court of Manila without jurisdiction over a complaint filed against him by respondent Crispina de Leon. The complaint alleged that de Leon owned a building leased to Nicomedes on a month-to-month basis at P300 monthly since February 1945; that on December 17, 1946, Nicomedes was notified the rent would increase to P400 starting January 1947; that Nicomedes failed to pay the increased rent and violated lease terms by not maintaining the premises; and that despite demands, he refused to pay and vacate. Nicomedes argued the suit was not an unlawful detainer case because it sought to collect P400, not the originally agreed P300.
ISSUE
Whether the Municipal Court of Manila had jurisdiction over the complaint, i.e., whether the allegations constituted a case for unlawful detainer under Rule 72 of the Rules of Court.
RULING
Yes. The Supreme Court affirmed the lower court’s ruling that the Municipal Court had jurisdiction. The complaint contained the essential elements of unlawful detainer: (a) plaintiff’s ownership; (b) a contract of lease on a monthly basis; (c) notice of termination or change of terms (increase to P400); and (d) the tenant’s failure to comply and retention of possession. The prayer for ouster, rents, and damages was typical in detainer suits. The Court distinguished the precedent in Belmonte vs. Marin, which addressed the merits of a similar claim (whether ejectment lies for non-payment of an unagreed rent increase) but did not question the inferior court’s original jurisdiction over the detainer action’s form. The alleged lease violations (e.g., failure to repair) were additional grounds supporting the main cause of action for termination and refusal to vacate. Under the Rules, unlawful detainer cases fall within the original jurisdiction of municipal or justice of the peace courts.
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