Case Digest (G.R. No. L-21381)
Facts:
Santiago Quimson v. Pablo Suarez, G.R. No. L-21381, April 05, 1924, the Supreme Court (Ostrand, J., ponente; Araullo, C.J., Johnson, Avancena, and Romualdez, JJ., concurring; Street, J., dissenting). Ostrand, J., wrote the opinion for the Court.The dispute arose from competing leases over a large fishpond in Orani, Bataan. On February 28, 1917, the deceased Pablo Tecson leased the pond to David Luna for ten years at an annual rent of P900; Luna assigned the lease to Pablo Suarez (the defendant-appellant) with Tecson’s consent. Tecson thereafter applied for registration of the land under Act No. 496 (the Torrens system), but died before final decree and title issuance; the final decree and certificate of title were issued in the names of Esperanza Tongco de Trias, administratrix of Tecson’s estate, and Maximiana Tongco, his widow, in equal shares, and made no mention of Suarez’s lease.
On May 23, 1920, Maximiana, as administratrix and guardian of Tecson’s heirs, and in her own behalf, executed a lease to Santiago Quimson (the plaintiff-appellee) for six years beginning May 1, 1921, with the total rent of P6,250 payable at execution; this lease was immediately noted by memorandum on the certificate of title. At execution Quimson knew Suarez was in physical possession and had been told by Maximiana that Suarez’s lease terminated March 1, 1921; there was no proof Quimson knew of any extension past that date. Separately, on November 15, 1920, Suarez filed an action in the Court of First Instance to set aside Quimson’s lease; that action, as far as the record showed, remained pending.
Quimson demanded possession on May 1, 1921; upon Suarez’s refusal Quimson filed a forcible entry and detainer action before the Justice of the Peace of Orani on May 6, 1921. Suarez objected to the magistrate’s jurisdiction; the justice overruled the objection, took cognizance, and awarded possession to Quimson and P280 damages. Suarez appealed to the Court of First Instance (CFI) of Bataan, appeared specially, and renewed a motion to dismiss for lack of jurisdiction, which the CFI denied. After a continuance and later denial of a sec...(Pro-only)
Issues:
- Did the trial court abuse its discretion in denying the defendant’s motion for a continuance?
- Was the Court of First Instance of Bataan vested with jurisdiction to hear the forcible entry and detainer action on appeal?
- Did the plaintiff’s registered lease entered on the certificate of title prevail over the defendant’s earlier, unregistered lease under Act No. 496, thereby extinguishing the defendant’s right...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)