G.R. No. 47184 - Romey vs. Roxas

Petitioner Vicente Romey filed an action in the municipal court of Manila to recover ₱148 from respondent Dionisio Saddie.
Respondent Saddie interposed a pleading, which he designated as a counterclaim, seeking not only the payment of unpaid rentals but also an order compelling Romey to vacate the leased house.
The municipal court rendered judgment dismissing Romey’s complaint for money and ordered him to pay the defendant’s unpaid rentals and to vacate the premises.

Romey was notified of the judgment on November 18, 1939, and he perfected his appeal eleven days later on November 29, 1939.
In the Court of First Instance of Manila, respondent Saddie moved for the execution of the judgment on his cross-complaint on the ground that Romey’s appeal was not perfected within ten days.
The Court of First Instance held that the appeal was timely as to the part of the judgment dismissing the money complaint but was untimely with respect to the part awarding the illegal detainer relief, given that such an appeal should have been perfected within ten days.

Although designated as a counterclaim, Saddie’s pleading was in truth a cross-complaint since it sought a non-monetary relief—namely, an order for illegal detainer.
Romey contended that the municipal court lacked jurisdiction to entertain the cross-complaint for illegal detainer, noting that there was no allegation in the pleading that required compliance with a five-day period following a demand to vacate, which is a jurisdictional requirement.
The facts show that a demand to vacate was indeed alleged in Romey’s complaint (stating that in August 1939, the defendant notified the plaintiff to vacate), while the cross-complaint was filed on September 14, 1939—more than five days after the demand.

The defendant asserted that, as the cross-complaint pertained to illegal detainer, the appeal should have been perfected within ten days.
The municipal court, acting within its limited jurisdiction, rendered judgment accommodating both the counterclaim (for rentals) and the cross-complaint (for illegal detainer), leading to a procedural anomaly regarding appeal deadlines.
The Court noted that inferior courts are limited by law and may not apply the broader rules governing the Courts of First Instance, particularly concerning cross-complaints outside the prescribed jurisdiction.

Whether the municipal court had jurisdiction to entertain a cross-complaint seeking illegal detainer when the claim did not comply with the jurisdictional requirement of alleging a five-day period following a demand to vacate.

Whether the pleading, though designated as a counterclaim, truly constituted a cross-complaint because it sought relief in the form of an order for illegal detainer in addition to monetary relief.

Whether the appeal by Romey was perfected in time with respect to both the monetary claim dismissal and the illegal detainer portion of the judgment.
How the anomalous situation—with differing deadlines for appeals on different parts of a single judgment—should be resolved under existing procedural laws.