G.R. No. L-3994 - Llobrera y Baylon vs. Director of Prisons

Antonio Co Tiamco, the petitioner, filed an action for unlawful detainer in the municipal court of Manila.
The subject matter involved a building located at No. 503 Sto. Cristo St., Manila, over which the defendants—Yao Boom Sim (alias Co Hue), Yao Ka Tiam (alias Chua Kui) and Sy Gui Gam (alias Go Si Pio)—were alleged to be in wrongful possession.

At trial in the municipal court, the petitioner introduced Exhibit A, a notice to quit, as evidence that defendants had been formally requested to vacate the premises prior to the filing of the action.
The defendant’s attorney objected on the ground that the notice to quit was not specifically pleaded in the complaint.
The municipal court sustained the objection and excluded the evidence on this technical basis.

In response, the petitioner filed an action for mandamus against the municipal court to compel the admission of Exhibit A.
The court issued a writ of mandamus (by Judge Mamerto Roxas) ordering that the evidence be admitted and that the trial continue.

Following the trial’s resumption and an eventual judgment in favor of the petitioner, the defendant appealed.
In the Court of First Instance of Manila, the respondent defendants filed a motion to dismiss the case on the ground that the complaint—reproduced in the appellate record—failed to allege the notice to quit.
The respondent court maintained that because the notice to quit was not included in the complaint, the municipal court had no original jurisdiction over the matter, and consequently, the appellate jurisdiction of the Court of First Instance was impaired.
Based on this theory, the motion to dismiss was granted and the case was dismissed.
Petitioner then brought an action for mandamus against the Court of First Instance of Manila, seeking the reinstatement of his case.

The complaint in the case was essentially a copy of Form No. 1 as provided in the Rules of Court, which has been traditionally used in unlawful detainer actions.
There was a controversy over whether such a form, when not supplemented with the explicit allegation of a notice to quit, is sufficiently pleading to confer jurisdiction on the municipal court.
Both the trial courts’ handling of the evidence (admission after mandamus) and the appellate court’s objection centered on the technical issue of the sufficiency of the pleading and its jurisdictional implications.

Is a complaint that is essentially a reproduction of the prescribed Form No. 1 (without an explicit allegation of a notice to quit) sufficient to confer jurisdiction on the municipal court in an unlawful detainer action?

Can the omission of the notice to quit from the complaint be remedied by the subsequent admission of evidence (Exhibit A) showing that such notice was served?

Does Rule 72’s requirement regarding a demand to quit apply jurisdictionally in all unlawful detainer actions, or is it limited to cases involving nonpayment or noncompliance with lease conditions rather than the termination or expiration of a lease?

Is a petition for mandamus appropriate to compel the Court of First Instance to reinstate and try the case on the merits when a dismissal is based solely on a technical alleged deficiency in the complaint?