G.R. No. L-22109 - Enaje vs. Ramos

The petitioner, Juan Enaje, initiated a civil action for the recovery of P85.00, with interest and attorneys’ fees, against respondent Felipe F. Dugan.
To enable him to prosecute the case in the Municipal Court of Gubat, Sorsogon, Juan Enaje sought to litigate as a pauper.

He had been the owner of several parcels of land.
These parcels had, over several years, been divided and partitioned among his children, who have now been in possession thereof and are paying the corresponding taxes.
He no longer owned or possessed any land parcel and had “no income or means of livelihood.”

Based on his affidavit, the petitioner sought authority to prosecute his case as a pauper litigant.

The Municipal Judge of Gubat, Sorsogon, denied the petition for authorization to litigate as a pauper.
This denial was influenced by a certificate from the Municipal Treasurer stating that a man by the name of Juan Enaje was the owner of lands indicated in Tax Declarations No. 1100 and No. 1106.
The petitioner contended that he was not the same Juan Enaje referenced in the treasurer’s certification, suggesting that the name might pertain to either the deceased Juan Enaje I or Juan Enaje II.

The petitioner filed a motion for reconsideration with emphasis on the fact that he had no income or means of livelihood, despite the certificate indicating property ownership under the disputed name.
His motion for reconsideration was rejected by the Municipal Judge.
The petitioner then moved the matter to the Court of First Instance of Sorsogon by way of certiorari.
While the Court of First Instance allowed him to proceed as a pauper and permitted the filing of a typewritten brief, it later ruled on June 4, 1963, that the Municipal Judge had not gravely abused his discretion.
The petitioner’s further motion for reconsideration was thwarted by the lower court’s order dated June 27, 1963.

The present case brought before the Supreme Court is an appeal from the orders of June 4 and June 27, 1963.
The central issue on appeal is whether the denial of pauper status—based primarily on the treasurer’s certificate showing a property ownership under the name Juan Enaje—constituted a grave abuse of discretion, considering the petitioner’s affidavit and claim of indigence.

Whether the petitioner should be allowed to litigate as a pauper in the Municipal (formerly Justice of the Peace) Court of Gubat, Sorsogon, despite a certificate indicating property ownership under the name Juan Enaje.
Whether the Municipal Judge committed a grave abuse of discretion in denying the petitioner’s application to proceed as a pauper litigant, in light of the petitioner’s affidavit asserting lack of income or means of livelihood.
Whether the factual determination of indigence should depend primarily on the litigant’s income—or the absence thereof—rather than on apparent property ownership, when evaluating the application for pauper status.