Case Summary (G.R. No. 204944-45)
Background of the Case
On October 18, 1943, Rafael Flameno executed a deed of absolute sale with Celestino Aguilar, transferring a parcel of land for P57,000. Concurrently, a lease agreement was made permitting Flameno to occupy the property for a total of ninety days, which expired on January 16, 1944. Following Flameno's refusal to leave after multiple demands from Aguilar, the latter filed a complaint for unlawful detainer on January 21, 1944.
Procedural History
Flameno contested the jurisdiction of the municipal court, asserting that the deed of sale and lease were fictitious and alleged the true nature of their agreement was a mortgage. This led the judge to dismiss the case without hearing evidence, relying on several reasons, including the assertion that ownership must first be resolved before addressing possession.
Jurisdictional Issues
The core of the case centers on the jurisdiction of the municipal court to hear unlawful detainer actions. The Court determined that the mere claim of ownership by Flames does not alter the nature of the action. In such possessory actions, the nature of the claims raised in the complaint is decisive. In this case, Aguilar sought ejectment based on the expiration of lease, not a declaration of ownership.
Mandamus as a Remedy
The Court addressed whether mandamus could issue against the municipal judge's dismissal of the case. It concluded that an appeal would not provide an expeditious resolution compared to mandamus, as there were no adequate alternative remedies available. The judge was therefore compelled to exercise his duty and hear the case.
Findings on Unlawful Detainer
The Court held that Aguilar's complaint was primarily an unlawful detainer action. The claim for damages was accessory and did not change the essence of the complaint. Flameno's assertion of ownership would not pr
...continue readingCase Syllabus (G.R. No. 204944-45)
Case Overview
- The case revolves around a petition for mandamus filed by Celestino Aguilar against Guillermo Cabrera, the judge of the Municipal Court of Manila, and Rafael Flameno.
- The main issue is the judge's dismissal of a complaint for unlawful detainer, which Aguilar sought to be heard and decided on its merits.
- The dismissal was based on the judge's belief that he lacked jurisdiction over the subject matter.
Factual Background
- On October 18, 1943, Rafael Flameno executed a deed of absolute sale, transferring ownership of a parcel of land located in Manila to Celestino Aguilar for P57,000.
- A written contract of lease was simultaneously entered into, allowing Flameno to occupy the property:
- Initial occupancy for thirty days without charge.
- An additional sixty-day occupancy subject to a rental of P150 per month.
- Flameno was required to vacate after the ninety days and indemnify Aguilar for any damages.
- Despite the lease's expiration on January 16, 1944, Flameno refused to vacate the premises.
- On January 21, 1944, Aguilar filed a complaint for unlawful detainer against Flameno in the Municipal Court.
Procedural History
- Flameno responded to Aguilar's complaint, claiming the deed of sale and lease were fictitious and stated he had initiated an action in the Court of First Instance to annul these contracts.
- The Municipal Court judge questioned