G.R. No. 80838 - Perez vs. Court of Appeals

On February 18, 1909, the plaintiffs (Juan Gumiran, Eusebio Gumiran, and Salvador Gumiran) filed a complaint in the Court of First Instance of the Province of Isabela.
The complaint pertained to the possession of a parcel of land described in the document, which the plaintiffs alleged had been in their possession from time immemorial.
Plaintiffs claimed absolute ownership and asserted that the defendant, Pio Gumiran, had unlawfully deprived them of the said land on May 6, 1908.
They sought a decree declaring their right to possession and ownership, the restoration of possession, payment of damages amounting to P500, costs of the case, and any additional relief the court deemed just and equitable.

The defendant, Pio Gumiran, responded by filing a demurrer based on jurisdictional grounds.
The demurrer argued that the subject matter of the complaint fell under the provisions of Section 80 of the Code of Civil Procedure, which grants original jurisdiction exclusively to justices of the peace in cases of illegal detainer or forcible entry.
It maintained that since the action was for illegal detainer (a summary action), the Court of First Instance lacked jurisdiction because the cause of action had occurred within one year from the alleged dispossession.

The case was called for trial on January 12, 1910, with attorneys representing both parties: Messrs. MacDougall and Concepcion for the plaintiffs, and Messrs. Hawkins and Harvey for the defendant.
Judge Richard Campbell, presiding over the case, evaluated the evidence and the legal arguments regarding jurisdiction and the nature of the action.
The lower court sustained the defendant’s demurrer, dismissing the plaintiffs’ complaint on the basis that the action was one for recovery under the summary procedure prescribed by Section 80, which required a waiting period of one year before filing in the Court of First Instance.

The plaintiffs appealed the lower court’s decision, raising three assignments of error:

That the complaint was erroneously characterized as a summary action under Section 80, thereby excluding it from the original jurisdiction of the Court of First Instance.
That the lower court’s ruling on the one-year limitation for instituting an action for recovery of possession and title was incorrect.
That sustaining the demurrer and dismissing the complaint was an error.

The factual timeline showed the action was commenced within one year of the alleged dispossession, but the plaintiffs contended that the nature of their claim—combining recovery of possession with a declaration of title—meant the special summary procedure did not apply.

Whether the Court of First Instance had jurisdiction to try an action that combined recovery of possession and determination of title, despite being filed within one year from the alleged dispossession.
Whether the complaint, by not specifically alleging the forcible entry or intimidation required by Section 80 of the Code of Civil Procedure, fell outside the exclusive jurisdiction of justices of the peace.

Whether the one-year period prescribed for actions under Section 80 applied to cases where the complaint simultaneously sought a declaration of ownership and repossession.
If the absence of explicit allegations of forcible entry, intimidation, or other qualifying factors meant the action was not a summary illegal detainer case.

Whether the plaintiffs’ complaint sufficiently distinguished its claims to place the action within the jurisdiction of the Court of First Instance.
Whether the failure to include the exact statutory language (pertaining to forcible entry and related acts) warranted the demurrer and dismissal by the lower court.