GR L 1855; (June, 1949) (Digest)
G.R. No. L-1855; June 22, 1949
FELIPE C. ALVIAR, ET AL., petitioners, vs. SANTOS B. PAMPOLINA, Justice of the Peace of San Pablo, Laguna, RURAL PROGRESS ADMINISTRATION and THE PROVINCIAL SHERIFF OF LAGUNA, respondents.
FACTS
Petitioners were tenants on land originally owned by Colegio de San Jose. In a prior case (Civil Case No. 6663), the Court of First Instance (CFI) of Laguna, affirmed by the Court of Appeals, ordered the tenants to vacate the land. The land was later purchased by the Commonwealth and placed under the Rural Progress Administration (RPA). The tenants filed a new action in the CFI (Civil Case No. 8039) seeking to nullify the title of Colegio de San Jose and the subsequent sale. Simultaneously, the RPA filed several forcible entry and detainer cases against the same tenants in the Justice of the Peace Court. The tenants moved to dismiss these ejectment cases, arguing that the pending action for title in the CFI deprived the Justice of the Peace of jurisdiction. The motion was denied, the ejectment cases were tried, and judgments were rendered against the tenants, which became final and executory. The tenants then filed the present petition for certiorari.
ISSUE
Whether the pendency of an action for title (ownership) in the Court of First Instance deprives the Justice of the Peace Court of jurisdiction over concurrent forcible entry and detainer cases involving the same property and parties.
RULING
No. The Justice of the Peace Court validly exercised jurisdiction. The pendency of an action for title in the CFI is not a bar to a simultaneous action for forcible entry and detainer in the inferior court. An action for ownership and an action for forcible entry and detainer are distinct remedies. Whether title is involved in the ejectment case is a question of fact to be determined from the evidence at trial and reviewed only on appeal, not via certiorari. Since the Justice of the Peace Court had jurisdiction, it had authority to try the cases, render judgments, and order their execution. The petition for certiorari was dismissed.
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