G.R. No. L-1091 - Cruz vs. Garcia

The respondent, Manuel Joaquin, initiated an ejectment suit in the justice of the peace court of Pasay, Rizal.
The suit was filed against Domingo Cruz and Crescencia Austria, who are the petitioners in the case.
The primary allegation in the complaint was that Manuel Joaquin had purchased a house located at No. 18 O'Farrell Street, Pasay, Rizal, from Eulalio Algoso on April 16, 1946.
It was further alleged that, prior to and at the time of the purchase, the petitioners were in possession of the said property.

In their answer, the petitioners asserted that they are the sole and absolute owners of the house in question.
They contended that Eulalio Algoso, the purported vendor in the sale, was never the owner of the property.
This defense fundamentally raised the issue of title, implying that the petitioners could not be ousted without a judicial determination that they were not the rightful owners.

The justice of the peace court, after denying a motion for dismissal raised by the petitioners, allowed the respondent to present his evidence.
The court subsequently rendered a judgment ordering the petitioners to vacate the house and to pay a monthly rental of P30.
On appeal to the Court of First Instance of Rizal, the petitioners reiterated their defenses based on their claim of absolute ownership.
The petitioners notably failed to deposit the monthly rental awarded by the justice of the peace court, prompting the respondent to move for immediate execution.
The petitioners argued for the dismissal of the complaint on grounds that the justice of the peace court lacked jurisdiction because the issue involved a question of ownership rather than a simple case of forcible entry or unlawful detainer.

They prayed that the order of execution be set aside, that the proceedings held before the justice of the peace court be declared null and void, and that the respondent judge desist from further proceedings in the case.

Both the pleadings in the justice of the peace court and in the Court of First Instance revolved around the central issue of ownership of the house.
Any question of possession that might be raised was inherently tied to the ultimate inquiry into the title.
The suit did not allege any cause of action for forcible entry or unlawful detainer as defined under Section 1 of Rule of Court No. 72, making the jurisdiction of the justice of the peace questionable.

Whether the justice of the peace court had proper jurisdiction over the case given that the central issue was one of ownership rather than forcible entry or unlawful detainer.
Whether the Court of First Instance acquired appellate jurisdiction over a case fundamentally involving a question of title.

Whether the petitioners’ claim as the sole and absolute owners of the property barred the respondent’s attempt to enforce an ejectment suit.
Whether the petitioners could be ousted from the property without a judicial finding that they are not its owners.

Whether the suit should have been dismissed by the justice of the peace court since the complaint did not allege a cause of action for forcible entry or unlawful detainer.
Whether the subsequent order for execution by the Court of First Instance was procedurally proper given the nature of the case.