Facts:

The case, Celestino Aguilar vs. Guillermo Cabrera and Rafael Flameno, was decided on June 30, 1944 (G.R. No. 49129). The petitioner, Celestino Aguilar, sought a writ of mandamus to compel the Municipal Court of Manila, presided over by respondent Judge Guillermo Cabrera, to hear and decide an unlawful detainer case that had been dismissed. The events began on October 18, 1943, when Rafael Flameno executed a deed of absolute sale in favor of Aguilar for a parcel of land in Manila, transferring ownership in exchange for P57,000. This sale was documented and registered, leading to the issuance of Transfer Certificate of Title No. 68575 in Aguilar's name. Along with the sale, a lease agreement was executed, stipulating a thirty-day lease followed by a sixty-day period at a monthly rent of P150. The lessee, Flameno, was required to vacate the premises at the end of ninety days.

Despite the expiration of this period on January 16, 1944, Flameno refused to vacate despite Aguilar’s

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Facts:

Background Transactions

• On October 18, 1943, Rafael Flameno executed a deed of absolute sale transferring a parcel of land in Manila, together with its buildings and improvements, to Celestino Aguilar for the sum of P57,000.
• The deed was duly registered, and transfer certificate of title No. 68575 was issued in Aguilar’s name.
• Simultaneously, a written contract of lease was executed between Aguilar (as owner) and Flameno (as lessee) on the same day.

Terms of the Contract of Lease

• The lease granted the lessee free occupancy for an initial period of thirty (30) days from October 18, 1943.
• After the initial free period, the lessee was allowed an additional period of sixty (60) days, during which he was obligated to pay a monthly rental of P150 (payable in advance within the first five days of each month).
• Upon the expiration of the total ninety (90) days, ending January 16, 1944, the lessee was required to vacate the premises "promptly and peacefully" and to indemnify the owner for any consequent damages or losses.

Breach and Commencement of Proceedings

• Despite the lease’s clear stipulation, Flameno refused to vacate the premises after the lapse of the ninety-day period.
• On or about January 21, 1944, Aguilar instituted an action before the Municipal Court of Manila, filing a complaint for unlawful detainer.
• The complaint sought ejectment of Flameno from the premises.
• It also demanded reimbursement of P174.52 for taxes paid on behalf of Flameno, damages amounting to P1,500, and additional monthly sums of P500 for the use of the premises.

Defendant’s Response and Counterclaims

• On January 28, 1944, Flameno filed a written answer alleging that the deed of sale and the contract of lease were fictitious and simulated.
• Flameno concurrently initiated a separate action in the Court of First Instance seeking:
• Annulment of the deed of sale and the lease contract.
• A declaration that the true agreement was a mortgage of the property in his favor for P50,000 with interest.
• An order directing the cancellation of transfer certificate of title No. 68575 and the issuance of a new title in his name.

Judicial Proceedings and Dismissal

• At trial, Flameno’s counsel challenged the jurisdiction of the Municipal Court, arguing that the case involved issues of ownership rather than mere possession.
• The judge required the parties to submit written memoranda concerning the question of jurisdiction.
• Meanwhile, Aguilar filed an amended complaint intended to conform with the ejectment form prescribed in the Rules of Court, aiming to simplify the issues.
• On February 29, 1944, the Municipal Court judge rendered an order rejecting the amended complaint and dismissing the original complaint on several grounds:
• The plaintiff admitted never having possessed the premises, thereby allegedly lacking standing to institute an ejectment action.
• The resolution of possession could not occur independently of clarifying the issue of ownership.
• Both the deed of sale and the contract of lease were being simultaneously challenged in the Court of First Instance as fictitious and simulated.
• The claim for breach of contract damages and the monetary amounts involved exceeded the jurisdictional limits of the Municipal Court.
• The amendment substantially altered the nature of the action from its original pleading.

Mandamus Petition and Questions Raised

• Aguilar subsequently filed a petition for mandamus, seeking to compel the respondent judge to hear and decide the merits of the case.
• The petition raised two central questions:
• Whether mandamus is an available remedy in a situation where a judge, erroneously believing he lacks jurisdiction, refuses to hear a case.
• Whether the case, as framed by the allegations and relief sought in the complaint, qualifies as an action of unlawful detainer within the proper jurisdiction of the Municipal Court.

Issue:

• Whether a writ of mandamus is available to compel a judge to exercise his jurisdiction when he erroneously refuses to hear and decide on the merits of an unlawful detainer case.
• Whether the case as presented by the petitioner is properly characterized as an unlawful detainer (possessory action) within the Municipal Court’s subject-matter jurisdiction, notwithstanding the defendant’s claim in his answer that the dispute involves issues of title and ownership.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)