Case Digest (G.R. No. L-36208)
Facts:
The case involves Ambo Alilaya as the petitioner and Marcela de Espanola, assisted by her husband Teopisto Espanola, as the respondents. The events leading to this case began with a decision rendered by the City Court of General Santos City, presided over by Judge Armie E. Elma, in an action for forcible entry and damages, specifically Civil Case No. 587-II. The City Court ruled in favor of Alilaya, dismissing the counterclaim of the defendants, the Espagnolas. The Espagnolas appealed this decision to the Court of First Instance of South Cotabato, where Judge Pedro Samson C. Animas presided. The Court of First Instance reversed the City Court's decision, asserting that the City Court had acted without jurisdiction because the issue of ownership was intertwined with that of possession. Alilaya contended that the City Court had jurisdiction over the case, as Republic Act No. 5967 provided concurrent jurisdiction with the Court of First Instance in ejection cases where owner...
Case Digest (G.R. No. L-36208)
Facts:
- Case Background: The case originated from a decision by the City Court of General Santos City in Civil Case No. 587-II, involving an action for forcible entry and damages. The plaintiff (petitioner Ambo Alilaya) was awarded possession, and the defendants' (private respondents Marcela de Espanola and Teopisto Espanola) counterclaim was dismissed.
- Appeal to the Court of First Instance: The defendants appealed to the Court of First Instance of South Cotabato, which reversed the City Court's decision, holding that the City Court lacked jurisdiction because the issue of ownership was intertwined with possession.
- Petitioner's Motion for Reconsideration: The petitioner moved for reconsideration, citing Republic Act No. 5967, which grants City Courts concurrent jurisdiction with the Court of First Instance in ejectment cases where ownership is raised. The motion was denied.
- Urgent Motion for Execution: The petitioner filed an "Urgent Motion for Execution" with the City Court, arguing that the decision had become final and executory since the appeal was improperly taken to the Court of First Instance instead of the Court of Appeals or Supreme Court. The motion was denied by the City Court, which claimed it had lost jurisdiction due to the pending appeal.
- Main Issue: The central issue is whether the Court of First Instance properly assumed jurisdiction over the appeal and reversed the City Court's decision, given that the issue of ownership was intertwined with possession.
Issue:
- Jurisdiction of the City Court: Whether the City Court of General Santos City had jurisdiction over the forcible entry case despite the issue of ownership being raised.
- Proper Forum for Appeal: Whether the appeal from the City Court's decision should have been taken to the Court of Appeals or Supreme Court, rather than the Court of First Instance, under Republic Act No. 5967.
- Validity of the Court of First Instance's Decision: Whether the Court of First Instance acted without jurisdiction in entertaining the appeal and reversing the City Court's decision.
- Finality of the City Court's Decision: Whether the City Court's decision had become final and executory due to the improper appeal to the Court of First Instance.
Ruling:
The Supreme Court granted the petition, setting aside the decision and order of the Court of First Instance. The Court held that:
- City Court's Jurisdiction: The City Court of General Santos City had jurisdiction over the forcible entry case, even though the issue of ownership was raised, as provided under Republic Act No. 5967.
- Improper Appeal: The appeal should have been taken to the Court of Appeals or Supreme Court, not the Court of First Instance, as the latter lacked jurisdiction over the appeal.
- Finality of Decision: The City Court's decision had become final and executory due to the improper appeal, and the Court of First Instance's decision was declared null and void.
- Execution of Judgment: The City Court's denial of the motion for execution was sustained, but the petitioner was allowed to file another motion for execution based on the finality of the decision.
Ratio:
- Concurrent Jurisdiction: Under Republic Act No. 5967, City Courts have concurrent jurisdiction with the Court of First Instance in ejectment cases where the issue of ownership is raised. The City Court of General Santos City properly exercised this jurisdiction.
- Improper Forum for Appeal: Appeals from City Court decisions in such cases must be taken to the Court of Appeals or Supreme Court, not the Court of First Instance. The Court of First Instance acted without jurisdiction in entertaining the appeal.
- Finality of Judgment: The City Court's decision became final and executory because the appeal was improperly taken to the Court of First Instance, which lacked jurisdiction. The Court of First Instance's decision was therefore null and void.
- Substantial Justice: The designation of the action as "forcible entry and damages" clearly indicated the reliefs sought, and the lack of explicitness in the City Court's decision did not hinder the attainment of substantial justice.