G.R. No. L-15700; April 26, 1961
CRESENCIA VDA. DE BAKIT, petitioner-appellee, vs. VERONICO ASPERIN and FELIX T. JAMERO, as Justice of the Peace of Loreto, Surigao, respondents-appellants.

FACTS

Respondent Veronico Asperin filed an ejectment complaint (Civil Case No. 14) against petitioner Cresencia Vda. de Bakit in the Justice of the Peace Court of Loreto, Surigao. Asperin alleged he was the owner of a parcel of land by virtue of a “Sale with Conventional Redemption” from Bakit, and that Bakit subsequently became his tenant but violated their tenancy contract by failing to deliver his share of harvests. He sought her ejectment and damages. In her answer, Bakit claimed ownership of the land, asserting that the document was not a true sale but merely a mortgage to secure a debt, and she prayed for reformation of the instrument. The justice of the peace court rendered a decision in favor of Asperin, ordering Bakit to vacate the land and pay monthly compensation. Bakit initially appealed to the Court of First Instance (CFI) but her counsel withdrew the appeal. Later, through new counsel, she filed a petition for relief from judgment, which was also withdrawn. Subsequently, she filed a “Petition for a Writ of Certiorari with Preliminary Injunction” in the CFI, contending the justice of the peace court lacked jurisdiction because the case involved a determination of title to real property and a tenancy dispute, matters beyond its competence.

ISSUE

Whether the Justice of the Peace Court of Loreto had jurisdiction over Civil Case No. 14.

RULING

The Supreme Court affirmed the CFI’s decision, ruling that the justice of the peace court lacked jurisdiction. The legal logic is grounded on the nature of the issues presented. Asperin’s complaint, while framed as an ejectment action based on a tenancy violation, ultimately relied on his claim of ownership derived from the “Sale with Conventional Redemption.” Conversely, Bakit’s defense directly put title in issue by asserting ownership and claiming the document was a mortgage. As held in Teodoro vs. Balatbat, when the right to possession depends upon the resolution of a question of ownership, the case is beyond the jurisdiction of an inferior court. Furthermore, if the relationship was truly one of agrarian tenancy, jurisdiction would exclusively belong to the Court of Agrarian Relations. In either scenario—whether the core issue was ownership or a tenancy dispute—the justice of the peace court had no jurisdiction. Consequently, all proceedings, including its decision, were null and void ab initio. The Court also held that while a certiorari petition typically requires the absence of appeal, the pleading could be treated as an ordinary action for annulment of judgment due to the jurisdictional defect.