Facts:

Regino G. Aquisap, the plaintiff-appellant, filed a case against Eugenio Basilio and Santiago Amos on July 28, 1943, designated as "Civil Case No. 1, por Detentacion," with the justice of the peace court in San Marcelino, Zambales. The court rendered a judgment on September 25, 1943, which required the defendants to vacate the land, restore possession to Aquisap, and pay damages and costs. Despite receiving the judgment, Basilio continued to occupy the land, farming it with palsy during the years 1944, 1945, and 1946, yielding an estimated total of 48 cavanes of palsy. On October 23, 1946, a writ of execution was issued, and by November 1946, the deputy sheriff executed the judgment by transferring possession of the land back to Aquisap. Subsequently, on December 10, 1946, Aquisap filed a further complaint for the recovery of damages stemming from Basilio's illegal possession during the previous years. However, this complaint (CC 1150) was dismissed on July 29, 195

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Facts:

Background of the Case

• In 1943, Regino G. Aquizap filed “Civil Case No. 1, por Detentacion, dated July 28, 1943” with the Justice of the Peace Court of San Marcelino, Zambales against Eugenio Basilio and Santiago Amos.
• The case involved a claim for possession of land, with Aquizap seeking not only the recovery of possession but also damages and costs.

Proceedings in the Lower Court

• On September 25, 1943, the court rendered a decision directing Basilio to vacate and restore possession of the land and to pay damages and costs.
• Despite receiving a copy of the decision, Basilio retained possession of the land where he cultivated palsy during the agricultural years 1944, 1945, and 1946.
• Basilio is alleged to have exclusively harvested a total of 48 cavanes of palsy (16 per year) from the said land.

Execution of the Judgment and Subsequent Actions

• In November 1946, by virtue of a writ of execution issued on October 23, 1946, the deputy sheriff of Zambales forcibly removed Basilio and delivered possession of the land to Aquizap.
• On December 10, 1946, Aquizap initiated a complaint (CC 1150) in the Court of First Instance of Zambales seeking monetary recovery and damages for the alleged unlawful retention and use of the land.
• This complaint was dismissed on July 29, 1953 due to Aquizap’s failure to appear during the hearing, with the dismissal being “without prejudice to the filing of a new complaint.”

Filing of the Present Action and Subsequent Development

• On November 3, 1953, Aquizap filed a new action (CC 1631) with the same court detailing that Basilio’s illegal possession caused him damages amounting to the value of 48 cavanes of palsy (priced at P11 per cavan), totaling P528, as well as an additional P200 for other damages and professional expenses.
• The amended complaint reasserted the allegations of the first complaint while adding a paragraph to substitute the deceased Eugenio Basilio with his heirs and successors in interest (including Luciano, Ceferino, Francisca, Pio, Silverio, Ricardo, Tomas, Florentino, and Maria Concepcion Basilio).
• The heirs-defendants moved to dismiss the amended complaint on grounds that it did not state a cause of action, did not accrue against them, and was barred by the statute of limitations.

Jurisdictional and Procedural Considerations

• The lower court dismissed the amended complaint on the basis that it was barred by the statute of limitations.
• A key point of contention was that the original 1946 action was dismissed “without prejudice,” leaving room for a new complaint; however, the current action was subject to the law in force at the time of its filing (1953).
• By 1953, the Judiciary Act of 1948 was in force, which granted inferior courts exclusive original jurisdiction only for claims with an amount exceeding a minimum threshold (initially P2,000, notwithstanding later increases).
• The total demands in Aquizap’s amended complaint were clearly below this threshold, thereby triggering issues of lack of jurisdiction and statute of limitations.

Issue:

Jurisdiction

• Whether the Court of First Instance had jurisdiction over a new action filed in 1953 when the claim amount was below the prescribed minimum (as per the Judiciary Act of 1948).
• Whether the dismissal of the earlier 1946 action – although noted “without prejudice” – discharged the lower court’s jurisdiction and necessitated that the present action conform to the current statutory limits.

Procedural Validity and Statute of Limitations

• Whether the amended complaint, filed after the dismissal of the original 1946 action, was barred by the statute of limitations.
• Whether the substitution of defendants (heirs of Basilio) properly accounted for procedural requirements in stating a cause of action against them.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)