G.R. No. L-29275 January 31, 1972
FLORENTINO PANGILINAN, ET AL., petitioners, vs. THE HONORABLE ANDRES AGUILAR, Judge of the CFI of Pampanga, Branch III, ET AL., respondents.

FACTS

Private respondents, as plaintiffs, filed an unlawful detainer case against petitioners in the Angeles City Court concerning Lot No. 681. Petitioners moved to dismiss, arguing the city court lacked jurisdiction and the complaint stated no cause of action, claiming the land was state patrimonial property they had acquired by prescription. The city court denied the motion and, after petitioners unsuccessfully challenged this denial via a certiorari petition in the Court of First Instance (CFI) and subsequently withdrew their appeal, proceeded to trial. The city court ruled against petitioners, ordering them to vacate and pay rentals.
Petitioners then appealed the judgment to the CFI but did not file a supersedeas bond. In the CFI, they filed a motion to dismiss their own appeal, contending the CFI should try the case under its original, not appellate, jurisdiction because the issue of ownership was allegedly involved. The respondent CFI judge denied this motion and, upon private respondents’ motion, dismissed the appeal for failure to file a supersedeas bond and issued a writ of execution. Petitioners then filed this certiorari and prohibition petition with the Supreme Court.

ISSUE

Whether the respondent CFI judge acted with grave abuse of discretion in dismissing petitioners’ appeal from the city court’s judgment and in issuing a writ of execution.

RULING

No. The respondent judge acted correctly and within his jurisdiction. The Supreme Court held that the perfection of an appeal from an inferior court to the CFI confers appellate jurisdiction upon the latter. The filing of a supersedeas bond is a mandatory requirement under the Rules of Court for staying execution of the judgment in ejectment cases. Petitioners’ failure to file such a bond rendered their appeal ineffective for staying execution, and the duty of the CFI to dismiss the appeal for this failure becomes ministerial.
Petitioners’ argument—that the appeal was merely to elevate the case for original trial by the CFI due to the raised issue of ownership—is untenable. The jurisdiction of the court is determined by the allegations in the complaint. The complaint was one for unlawful detainer, clearly within the original jurisdiction of the city court. The defense of ownership raised by petitioners does not divest the city court of its jurisdiction over the possessory action. Consequently, the CFI properly exercised its appellate, not original, jurisdiction over the appealed case. The dismissal of the appeal for non-compliance with the bond requirement and the issuance of the writ of execution were thus valid and legal acts. The petition was dismissed.