Facts:

This case, Maria Salud Angeles vs. Pedro Guevara, originated in the Justice of the Peace Court in Bacolor, Pampanga, where the plaintiff-appellee Maria Salud Angeles filed a complaint on March 17, 1954. Angeles alleged that she was the registered owner of Lot No. 828 from the Cadastral Survey of Bacolor, which included a house and other improvements, following her purchase of the property on February 4, 1954. She requested the defendant-appellant, Pedro Guevara, to vacate the premises since he had been residing there illegally. Needed resolution prompted Angeles to pray for the defendant’s eviction and payment of monthly rent of P100.00 for his continued possession, along with cost of suit. The defendant initially did not respond but later filed a motion to dismiss, arguing that the complaint failed to show a cause of action and that the Justice of the Peace Court lacked jurisdiction due to the ownership issue involved. Despite the motion being denied, the defendant answered the

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Facts:

1. Ownership and Purchase of the Property

   • Maria Salud Angeles (plaintiff-appellee) filed a complaint in the Justice of the Peace Court of Bacolor, Pampanga, on March 17, 1954.
   • She claimed to be the registered owner of Lot No. 828 of the Bacolor Cadastre, including a house and improvements, which she purchased on February 4, 1954.
   • She and her predecessor-in-interest had requested Pedro Guevara (defendant-appellant) to vacate the premises, but he refused.
   • Plaintiff sought Guevara’s ejectment and payment of P100.00 monthly rent from February 4, 1954, until he vacated.

2. Defendant’s Defense and Counterclaim

   • Guevara moved to dismiss the complaint, arguing that the Justice of the Peace Court lacked jurisdiction due to the involvement of ownership issues.
   • He claimed that the sale to Angeles was illegal and fictitious.
   • Guevara alleged he had been in possession of the property for about ten years and had entered into an agreement with Alfredo Lacdao (guardian of the minors who owned the property) to purchase it for P5,000.00, with a down payment of P430.00.
   • He also filed a counterclaim seeking reimbursement for improvements (P7,000.00) and damages (P1,000.00).

3. Trial Court Proceedings

   • The Justice of the Peace Court denied Guevara’s motion to dismiss and ruled in favor of Angeles, ordering Guevara to vacate and pay P60.00 monthly rent.
   • Guevara appealed to the Court of First Instance, which also denied his motion to dismiss and upheld the lower court’s decision.
   • The Court of First Instance found Angeles to be the rightful owner and dismissed Guevara’s counterclaim.

4. Appeal to the Supreme Court

   • The Court of Appeals certified the case to the Supreme Court due to jurisdictional issues.

Issue:

1. Jurisdiction of the Justice of the Peace Court

   • Whether the Justice of the Peace Court had jurisdiction over the case, given that the main issue involved ownership of the property.

2. Correctness of the Court of First Instance’s Decision

   • Whether the Court of First Instance correctly exercised its original jurisdiction and ruled on the merits of the case.

3. Reasonableness of the Monthly Rental

   • Whether the P60.00 monthly rental fixed by the trial court was reasonable.

4. Defendant’s Claim for Reimbursement

   • Whether Guevara was entitled to reimbursement for repairs and improvements made on the property.

5. Prejudicial Question of Ownership

   • Whether the separate civil action filed by Guevara raised a prejudicial question that should have suspended the proceedings.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)