Facts:

• Celestino Aguilar is the petitioner, while Guillermo Cabrera (Judge of the Municipal Court of Manila) and Rafael Flameno are the respondents.
• On October 18, 1943, Rafael Flameno executed a deed of absolute sale for a parcel of land in Manila to Celestino Aguilar for P57,000.
• The deed was registered, and Transfer Certificate of Title No. 68575 was issued in Aguilar's name.
• A written lease contract allowed Flameno to occupy the property for ninety days, with specific rental terms and conditions for vacating.
• The lease expired on January 16, 1944, but Flameno refused to vacate despite Aguilar's demands.
• On January 21, 1944, Aguilar filed a complaint for unlawful detainer against Flameno in the Municipal Court of Manila, seeking possession, reimbursement for taxes, and damages.
• Flameno claimed the deed of sale and lease were fictitious, asserting the true agreement was a mortgage, and filed a separate action to annul the contracts.
• The judge dismissed Aguilar's complaint without hearing evidence, citing lack of jurisdiction over ownership issues and damages claims.
• Aguilar sought a writ of mandamus to compel the judge to hear the case.

Issue:

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Ruling:

• The Supreme Court ruled that mandamus is appropriate to compel the respondent judge to hear and decide the case on its merits.
• The Court held that the respondent...(Unlock)

Ratio:

• Mandamus is a proper remedy when a lower court unlawfully neglects to perform a duty mandated by law, especially when no other adequate remedy exists.
• The judge's dismissal of the complaint was based on an erroneous belief of lacking jurisdiction, constituting a neglect of duty.
• If the case is one of unlawful detainer, the municipal court is required by law to hear and decide it on the merits.
• The nature of the action should be ...continue reading