G.R. No. L-56700 - Mabalot vs. Madela, Jr.

This case is an unlawful detainer action originally commenced in the City of Manila by a private respondent seeking to eject the petitioners from an apartment located at No. 2262 Coral Street, San Andres, Manila.
The initial decision of the City Court favored the petitioners; however, it was subsequently appealed by the private respondent to the Court of First Instance of Manila.

The appeal was assigned to Judge Tomas P. Madela, Jr. of the Court of First Instance of Manila.
On January 6, 1981, Judge Madela rendered a decision that reversed the City Court’s ruling, ordering the petitioners to vacate the premises.
The petitioners then took a direct appeal, raising a pure question of law concerning alleged lack of jurisdiction by both the City Court and the Court of First Instance of Manila.

The apartment was originally leased by private respondent to Atty. Armando Galvez on a monthly basis (P200.00 per month) since 1967.
Defendant Araceli Mabalot resided in the apartment along with a maid who was claimed to be under the care of Atty. Galvez since childhood.
In 1970, Araceli Mabalot married defendant Warlito Mabalot, and despite the change in her marital status, she continued to reside in the apartment under the lease with Atty. Galvez.
Following the death of Atty. Armando Galvez on August 23, 1977, several pertinent events occurred:

For the months of July and August 1977, arrearages were paid by Atty. Fernando Galvez, brother of the deceased.
For September 1977, Atty. Fernando Galvez issued a check (pay to cash) for payment, although receipts were issued in his name.
The plaintiff-appellant, in a letter dated September 1, 1977, intimated that due to the personal nature of the lease, Araceli and her husband could not succeed to the lease.
Despite the letter's contents, the defendants eventually refused to acknowledge its receipt, leading to formal service with a patrolman as witness.

The petitioners advanced the argument that they should have the right to continue occupying the apartment by succeeding to the lease contract of the deceased Atty. Armando Galvez.
They questioned whether the lease, described as a personal contract not ordinarily inheritable (per Civil Code provisions), could nonetheless be transmitted to them, alleging that such legal infirmity in the proceedings compromised the lower courts’ jurisdiction.
The petitioners further contended that the action ought not to be classified strictly as an unlawful detainer since it involved the legal issue of lease succession, implying that its subject matter was beyond pecuniary estimation.

A major contention raised by the petitioners was that the City Court lacked jurisdiction because the subject matter of the case, revolving around inheritance of the lease, was allegedly not determinable in monetary terms.
Petitioners noted that an action for unlawful detainer must be filed within one year from the time the defendant’s possession became unlawful, asserting that the prolonged occupancy (since 1966) should preclude the claim for ejectment.
The factual timeline, however, indicated that possession only became unlawful after the death of Atty. Galvez, thereby validating the filing date of January 8, 1978, as within the prescribed one-year period.

Whether the petitioners (Warlito and Araceli Mabalot) have the lawful right to continue occupying the apartment under the lease contract originally established with Atty. Armando Galvez.

Does a lease contract—by its very nature personal and non-transmissible—allow for succession by heirs or other persons upon the death of the original lessee?
Is the contention that the lease is inheritable sufficient to reclassify the action from one of unlawful detainer to a case involving a subject matter incapable of pecuniary estimation?

Whether the lower courts, namely the City Court and the Court of First Instance of Manila, possess proper jurisdiction to hear and decide on an action that involves both the issue of unlawful detainer and the question of lease succession.

Specifically, does the delay in filing the case or the legal implications of inheritance affect the courts’ jurisdiction or make the action untimely under the statutory one-year filing period for unlawful detainer cases?