Case Digest (G.R. No. 209031)
Facts:
The case of Santiago Quimson vs. Pablo Suarez (G.R. No. 21381, April 5, 1924) involves an action for forcible entry and detainer regarding a fishpond located in Orani, Bataan. The plaintiff, Santiago Quimson, claimed entitlement to the property based on a lease he secured from the estate of the deceased Pablo Tecson, who originally leased the land on February 28, 1917, to one David Luna for ten years at an annual rent of P900. Subsequently, Luna assigned his lease to the defendant, Pablo Suarez, with the deceased owner's consent. Following Tecson's death, the land was registered under Act No. 496, but the final decree did not record Suarez's lease. Instead, a new lease was executed by Maximiana Tongco, Tecson’s widow and administratrix, that granted Quimson rights to the land for six years starting May 1, 1921, with a total payment of P6,250, which was duly recorded.
Despite Quimson's knowledge of Suarez's physical possession and that his lease would suppos
Case Digest (G.R. No. 209031)
Facts:
- Background and Parties
- The plaintiff, Santiago Quimson, claims entitlement to the possession of a fishpond property in Orani, Bataan based on a lease allegedly granted by the acting owner.
- The defendant, Pablo Suarez, asserts that he is in lawful possession of the same land under a prior lease also granted by the property’s owner.
- Chronology of Leasing and Title Registration
- On February 28, 1917, the deceased Pablo Tecson leased a large fishpond to David Luna for a ten‑year term at an annual rent of P900.
- Two months later, with Tecson’s consent, Luna assigned the lease to Pablo Suarez.
- Soon after, Tecson applied for registration of the land under Act No. 496. However, he died before the final decree and corresponding certificate of title could be issued.
- The final decree and certificate of title were issued in the names of Esperanza Tongco de Trias (as administratrix of Tecson’s estate) and Maximiana Tongco (his widow) in equal shares.
- Notably, the certificate of title did not mention Suarez’s lease.
- Subsequent Lease and Possession Conflict
- Following the issuance of the title, the administratrix role passed entirely to Maximiana Tongco, who, in her capacity as guardian of Tecson’s heirs and in her own behalf, granted a lease to the plaintiff, Quimson.
- The lease executed on May 23, 1920, was for a six‑year term beginning May 1, 1921, at a fixed total rent of P6,250, paid at the time of execution.
- This lease was promptly noted by memorandum on the certificate of title.
- At the time of Quimson’s lease execution, he had actual knowledge that Suarez was in possession as a tenant of Maximiana Tongco.
- Quimson was informed that Suarez’s lease purportedly expired on March 1, 1921.
- There is no evidence to show that Quimson was aware of any extension of Suarez’s lease beyond that date.
- Litigation and Procedural History
- On November 15, 1920, prior to Quimson’s possession claim, Suarez filed an action in the Court of First Instance seeking to set aside Quimson’s lease. This action appears to have been pending.
- On May 1, 1921, after formally demanding possession from Suarez without success, Quimson instituted the present action for forcible entry and unlawful detainer.
- The complaint was filed on May 6, 1921 in the court of the justice of the peace of Orani.
- Defendant Suarez challenged the jurisdiction of the justice of the peace, contending that the case was not one of forcible entry and detainer.
- The court overruled this objection and proceeded, eventually ordering Suarez to vacate the premises and to pay damages.
- On appeal, additional motions and continuances were sought and denied, leading to a trial in the Court of First Instance wherein final judgments were rendered in favor of the plaintiff.
Issues:
- Jurisdictional Scope of the Court
- Whether the action for forcible entry and unlawful detainer fell within the jurisdiction of the justice of the peace, specifically under Section 80 of the Code of Civil Procedure.
- Whether the objection to the trial court’s jurisdiction, based on the allegation that the case was not of forcible entry and detainer, was properly overruled.
- Timeliness and Effect of Procedural Motions
- Whether the trial court abused its discretion in denying the defendant’s petition for a continuance, considering the potential prejudice caused to the plaintiff’s counsel.
- Priority and Legal Effect of the Competing Leases
- Whether the unregistered (earlier) lease in favor of Suarez should hold priority over the subsequently registered lease executed by Quimson.
- Whether the failure to record the defendant’s lease upon the certificate of title renders it null and void for third parties dealing with the registered title.
- Whether the defendant’s right of possession was rightfully extinguished as of April 30, 1921, despite his earlier lease agreement.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)