Facts:

The case involves Domingo Cruz and Crescencia Austria as petitioners against Eulalio Garcia, the Judge of the Court of First Instance of Rizal, Manuel Joaquin, and the Provincial Sheriff of Rizal as respondents. The events leading to this case began when Manuel Joaquin filed an ejectment suit against Cruz and Austria in the Justice of the Peace Court of Pasay, Rizal, on April 16, 1946. Joaquin claimed to have purchased the house located at No. 18 O'Farrell Street, Pasay, from Eulalio Algoso, asserting that the petitioners were in possession of the property at the time of the purchase. In their defense, Cruz and Austria contended that they were the rightful owners of the property and that Algoso had never owned it. The Justice of the Peace Court denied the petitioners' motion to dismiss the case and allowed Joaquin to present evidence. Subsequently, the court ruled in favor of Joaquin, ordering the petitioners to vacate the premises and pay a monthly rental of P30.

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Facts:

1. Parties Involved:

   • Petitioners: Domingo Cruz and Crescencia Austria.
   • Respondents: Eulalio Garcia (Judge, Court of First Instance of Rizal), Manuel Joaquin, and the Provincial Sheriff of Rizal.

2. Property in Dispute:

   • A house located at No. 18 O'Farrell Street, Pasay, Rizal.

3. Claim of Manuel Joaquin:

   • He filed an ejectment suit in the justice of the peace court of Pasay, Rizal, alleging that he purchased the house from Eulalio Algoso on April 16, 1946.
   • He claimed that the petitioners (Cruz and Austria) were in possession of the house at the time of the purchase.

4. Defense of Petitioners:

   • They asserted that they are the sole and absolute owners of the property.
   • They denied that Eulalio Algoso was ever the owner of the house.

5. Proceedings in the Justice of the Peace Court:

   • The court denied the petitioners' motion to dismiss.
   • Manuel Joaquin presented his evidence, and the court ruled in his favor, ordering the petitioners to vacate the house and pay a monthly rental of P30.

6. Appeal to the Court of First Instance:

   • The petitioners reiterated their defenses.
   • They did not deposit the rental awarded by the justice of the peace court.
   • Manuel Joaquin moved for immediate execution, which the petitioners opposed, arguing that the justice of the peace court lacked jurisdiction because the case involved a question of ownership.
   • The Court of First Instance overruled the opposition and issued an order for execution.

7. Petition for Certiorari:

   • The petitioners filed an original petition for certiorari, seeking to set aside the order of execution, declare the proceedings in the justice of the peace court null and void, and prevent the respondent judge from further proceeding with the case.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Jurisdiction of the Justice of the Peace Court:

   • Under Section 1 of Rule of Court No. 72, the justice of the peace court has jurisdiction only over cases of forcible entry or unlawful detainer, where the issue is primarily about possession, not ownership.
   • Since the principal issue in this case was ownership, the justice of the peace court should have dismissed the case for lack of jurisdiction.

2. Appellate Jurisdiction of the Court of First Instance:

   • The Court of First Instance cannot acquire appellate jurisdiction over a case that was improperly filed in the justice of the peace court.

3. Invalidity of the Order of Execution:

   • The order of execution was based on a judgment rendered by a court without jurisdiction, making it null and void.

4. Precedents:

   • The Court cited similar cases, Penalosa and Penalosa vs. Garcia (78 Phil., 245) and Torres and Paglinawan vs. Pena (78 Phil., 231), to support its decision.