G.R. No. 56700 March 28, 1983
WARLITO MABALOT and ARACELI MABALOT, petitioners, vs. THE HON. JUDGE TOMAS P. MADELA, JR., in his capacity as Judge of the Court of First Instance of Manila and PEDRO V. MALIT, respondents.

FACTS

This case originated as an unlawful detainer action filed by respondent Pedro V. Malit to eject petitioners Warlito and Araceli Mabalot from an apartment in Manila. The property was leased by Malit to Atty. Armando Galvez on a monthly basis. Araceli Mabalot, claiming to be a ward of Atty. Galvez, resided in the apartment with him. After marrying Warlito, she continued living there until Galvez’s death on August 23, 1977. Following the death, Malit informed the petitioners and Galvez’s brother that the lease, being personal, was terminated and demanded that the Mabalots vacate within three months. The petitioners refused to leave.
The City Court of Manila initially ruled in favor of the Mabalots, but on appeal, the Court of First Instance, through Judge Madela, reversed the decision and ordered their ejectment. The petitioners then appealed directly to the Supreme Court, raising a pure question of law. They abandoned their earlier defense on the merits regarding succession to the lease and instead attacked the jurisdiction of the inferior courts.

ISSUE

Whether the City Court of Manila had jurisdiction over the complaint for unlawful detainer.

RULING

Yes, the City Court had jurisdiction. The Supreme Court dismissed the petition, upholding the lower courts’ jurisdiction. The petitioners’ jurisdictional attack was premised on two arguments: first, that the one-year prescriptive period for unlawful detainer had lapsed because Araceli’s occupancy began in 1966, and the suit was filed only in 1978; and second, that by alleging the lease could not be inherited, the complaint raised a question incapable of pecuniary estimation, vesting jurisdiction in the Court of First Instance.
The Court rejected both arguments. The one-year period for filing an unlawful detainer case is reckoned from the moment the defendant’s possession becomes unlawful, not from initial occupancy. The petitioners’ possession was lawful as members of Atty. Galvez’s household during his tenancy. Their possession became unlawful only upon the termination of the lease by Galvez’s death on August 23, 1977. The complaint filed on January 8, 1978, was well within the one-year period. On the second argument, the action remained one for unlawful detainer—a summary action for recovery of physical possession. The incidental legal question regarding the inheritability of the lease contract does not transform the nature of the action into one incapable of pecuniary estimation. To rule otherwise would deprive inferior courts of jurisdiction in numerous ejectment cases simply by raising a legal issue, undermining the summary nature of such proceedings intended for expeditious resolution.