G.R. No. L-16711, December 24, 1963
CRISTINO ORA-A, petitioner-appellee, vs. Judge JOSE M. ANGUISTA and PAZ BAYOT VDA. DE CORPUS, respondents-appellants.

FACTS

Paz Bayot Vda. de Corpus, an applicant for a foreshore lease from the government, filed an ejectment suit (Civil Case No. 163) in the justice of the peace court of Masbate against Cristino Ora-a. The complaint alleged that Ora-a, with her permission, constructed a house on the land, agreed to pay monthly rent, but later defaulted and refused to vacate. Ora-a moved to dismiss, arguing the court lacked jurisdiction because the land was public and Bayot’s lease application was unapproved, but the motion was denied. After trial, the municipal court ordered Ora-a to vacate, pay back rentals, and remove his improvements.
Instead of appealing this decision, Ora-a filed a petition for certiorari in the Court of First Instance (CFI) of Masbate. He contended the municipal court acted without jurisdiction, as the case allegedly involved ownership of land and Bayot was illegally commercializing public land. The CFI granted the petition, annulling the municipal court proceedings. It ruled that the municipal court lost jurisdiction because the case necessitated resolving questions of ownership and the legality of Bayot’s sub-lease, given her status as a mere applicant and not an approved lessee of the foreshore land.

ISSUE

Whether the Court of First Instance correctly annulled the municipal court’s decision via certiorari on the grounds of lack or excess of jurisdiction.

RULING

No, the CFI erred. The Supreme Court reversed the CFI’s order and denied the petition for certiorari. The municipal court validly exercised jurisdiction. First, the complaint was plainly one for unlawful detainer, based on a sub-lease agreement, default in rent, and refusal to vacate. Such actions for possession fall within the original jurisdiction of municipal courts. The issue was Bayot’s right to possess as a lessee/applicant, not ownership. Neither party claimed ownership; Bayot asserted rights under her lease application, and Ora-a did not assert ownership in himself. The defense questioning the validity of Bayot’s sub-lease, due to the unapproved application, did not convert the action into one involving title.
Second, certiorari was an improper remedy. Any error in the municipal court’s evaluation of the evidence—including the factual question of the status of Bayot’s lease application and the legality of the sub-lease—was an error in the exercise of jurisdiction, not a lack of it. The proper recourse for such an error was a regular appeal, not a special civil action for certiorari. The jurisdiction of the municipal court was conferred by the allegations of the compliant for detainer, and that jurisdiction was not ousted by the nature of the defenses presented. The Supreme Court emphasized that whether title is necessarily involved in a detainer case is a question of fact reviewable only on appeal.