GR L 3883; (July, 1950) (CRITIQUE)
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THE AI-ASSISTED CRITIQUE
The municipal court’s refusal to adjudicate the desahucio action based on a perceived lack of jurisdiction constitutes a fundamental error. Under the then-governing Rules of Court, specifically Rule 72, summary actions for ejectment fell within the exclusive original jurisdiction of municipal courts, regardless of any ancillary claims for damages or rescission raised by the defendant. The respondent judge improperly conflated the summary nature of an unlawful detainer proceeding with the plenary action for rescission pending in the Court of First Instance. The doctrine of hierarchy of courts and the principle of concurrent jurisdiction are inapplicable here; the municipal court had a mandatory, non-discretionary duty to resolve the possessory issue based on the pleadings and evidence before it, not to defer to another court based on the complexity of underlying contractual disputes.

The court’s reliance on Articles 1554 and 1556 of the old Civil Code to justify abdicating jurisdiction is a misapplication of substantive law to a jurisdictional question. While those articles govern the reciprocal obligations in a lease and the remedy of rescission, they do not divest a court of its statutory jurisdiction. The respondent judge essentially conducted a premature trial on the merits of the rescission claim, which was the very subject of the separate case in the Court of First Instance, and then used that analysis to decline jurisdiction over the distinct summary proceeding for ejectment. This reasoning violates the principle that jurisdiction is conferred by law, not by the nature of the defenses interposed. The proper course was to proceed with the desahucio case; any judgment rendered would be without prejudice to the separate action for rescission, adhering to the maxim res judicata only as to the issue of possession.

The Supreme Court’s grant of mandamus was correct and necessary to compel the performance of a ministerial duty. The writ of mandamus lies precisely to order a lower court to exercise jurisdiction it unlawfully declined. The respondent judge’s order to transmit the records effectively suspended the summary remedy intended by the rules, prejudicing the lessor’s right to a speedy resolution on possession. The ruling reinforces that defenses challenging the validity or demanding the rescission of the lease contract do not oust the municipal court’s jurisdiction in an ejectment suit; such defenses merely address the ultimate merits but do not affect the court’s authority to hear the case. This prevents litigants from frustrating the summary process by initiating parallel suits for rescission in courts of general jurisdiction.