Facts:

The case of Paz Jarin et al. vs. Daniel Sarinas et al. (G.R. No. L-2926) was decided on May 10, 1951. The dispute arose from a mortgage agreement executed on December 20, 1944, wherein Daniel Sarinas, the mortgagor, conveyed a property located in the Imus Estate Subdivision, Cavite, to Paz S. Jarin, Felicisima A. Palma, and Trinidad Palma, the mortgagees, in exchange for P25,000. The agreement stipulated that if the mortgagor paid the sum of P25,000 along with the fruits of five mango trees as interest within two years, the mortgage would be discharged. Subsequently, on January 20, 1945, Sarinas acknowledged receipt of an additional P25,000, securing the same property, with a payment period aligned with the first mortgage. On February 19, 1945, he signed another document acknowledging receipt of P50,000 in Japanese military notes and agreed to pay P2,000 in genuine currency at the end of the original term.

After the term expired, the mortgagees demanded payment, but the ...

Facts:

1. Mortgage Agreement:
On 20 December 1944, Paz S. Jarin, Felicisima A. Palma, and Trinidad Palma paid P25,000 to Daniel Sarinas in exchange for a mortgage on Lot No. 967 of the Imus Estate Subdivision, Cavite, including the house and improvements. The agreement stipulated that if Sarinas repaid the P25,000 and the fruits of five mango trees as interest within two years, the mortgage would be discharged.

2. Additional Loan:
On 20 January 1945, Sarinas and his wife acknowledged receiving another P25,000, secured by the same property, with repayment terms aligned with the first mortgage.

3. Japanese Military Notes:
On 19 February 1945, Sarinas and his wife signed a document acknowledging receipt of P50,000 in Japanese military notes, agreeing to repay P2,000 in genuine currency after the two-year term.

4. Refusal to Pay:
After the agreed period, Sarinas refused to pay the P2,000, claiming the Japanese military notes had no value.

5. Legal Action:
On 7 August 1948, the creditors filed a lawsuit to recover P2,000, lawful interest from 20 December 1944, and costs.

6. Moratorium Defense:
The defendants moved to dismiss the complaint, citing Executive Orders Nos. 25 and 32, which suspended debt payments. The trial court initially denied the motion but later dismissed the complaint, ruling that the moratorium applied and the plaintiffs could refile after its removal.

7. Appeal:
The plaintiffs appealed, arguing that Republic Act No. 342 lifted the moratorium for debts contracted during the enemy occupation and challenged the constitutionality of the executive orders.

8. Jurisdictional Issue:
The Court noted that the demand was for P2,000, placing the case under the exclusive jurisdiction of the Justice of the Peace Court, not the Court of First Instance.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction:
   Under Section 44(c) and Section 88 of the Judiciary Act of 1948 (Republic Act No. 296), the Justice of the Peace Court has exclusive original jurisdiction over cases where the demand does not exceed P2,000, exclusive of interest and costs. Since the plaintiffs sought only P2,000, the Court of First Instance had no jurisdiction.

2. Moratorium:
   The Court did not rule on the constitutionality of the moratorium or its applicability to the debt, as the jurisdictional issue was dispositive.

3. Proper Forum:
   The plaintiffs should have filed their case in the Justice of the Peace Court, not the Court of First Instance.