Title
Andres vs. Soriano
Case
G.R. No. L-10311
Decision Date
Jun 29, 1957
Petitioners sued respondents for detainer; ownership dispute arose. Municipal Court lacked jurisdiction; Court of First Instance assumed original jurisdiction, denying execution. Supreme Court upheld ruling, citing jurisdictional issues and procedural lapses.
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Case Digest (G.R. No. L-10311)

Facts:

  1. Parties Involved:

    • Petitioners: Emilio J. Andres and Paz Basa Andres.
    • Respondents: Hon. E. Soriano, Ruperto Lising, and Nenita Reyes Lising.
  2. Nature of the Case:

    • The petitioners filed an action for detainer against the respondent Lisings in the Municipal Court of Manila on 17 August 1955.
  3. Judgment of the Municipal Court:

    • The Municipal Court ruled in favor of the petitioners, ordering the respondent Lisings to vacate the premises and pay P30 monthly for the use and occupation of the premises starting June 1955, plus P50 for attorney's fees and costs.
  4. Appeal to the Court of First Instance:

    • The respondent Lisings appealed the decision to the Court of First Instance of Manila, filing the necessary notice of appeal and bonds.
  5. Motion for Execution:

    • During the pendency of the appeal, the petitioners moved for execution of the Municipal Court's judgment on 11 January 1956, alleging that the respondent Lisings failed to pay or deposit the monthly rental for December 1955 within the first 10 days of January 1956.
  6. Respondents' Objection:

    • The respondent Lisings objected to the motion for execution.
  7. Court of First Instance's Ruling:

    • On 24 January 1956, the Court of First Instance denied the motion for execution, stating that the Municipal Court lacked jurisdiction because the case involved a question of ownership or title to the premises. The court set the case for trial on the merits under its original jurisdiction.
  8. Claims of Ownership:

    • Both parties claimed ownership of the premises:
      • Petitioners claimed ownership of the building at 14-C Lerma, Sampaloc, Manila, and asserted that Ruperto Lising was allowed to reside there as their employee in charge of a billiard hall.
      • Respondents denied the petitioners' claim, asserting that they were the owners of the building and that the petitioners were their tenants under a lease agreement dated 14 June 1954.
  9. Petitioners' Basis for Ownership:

    • The petitioners based their claim on an agreement of sale dated 21 July 1954, which the respondents contested, alleging deception and misrepresentation.
  10. Contract of Lease:

    • The petitioners argued that a landlord-tenant relationship existed based on a contract of lease dated 22 July 1954, which allowed Ruperto Lising to occupy the premises as an employee. However, this contract was not attached to the complaint as required by the rules.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction of Municipal Courts:

    • Municipal Courts have no jurisdiction over cases where the question of ownership or title to the premises is involved. Such cases fall under the original jurisdiction of the Court of First Instance.
  2. Execution of Judgment:

    • Execution of a judgment cannot proceed if the court rendering the judgment lacked jurisdiction over the subject matter.
  3. Attachment of Contracts:

    • A contract relied upon as the basis of a claim must be attached to the complaint and pleaded as required by the rules. Failure to do so undermines the claim.
  4. Conclusive Presumptions:

    • The principle that a tenant cannot deny the landlord's title at the commencement of the landlord-tenant relationship (Section 68(6), Rule 123) does not apply if the contract establishing the relationship is not properly pleaded or attached to the complaint.


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