Case Summary (G.R. No. L-58912)
Facts of the Case
The petitioner, Roberto R. de Luzuriaga, Sr., and 15 other individuals filed Civil Case No. 13336 in the Court of First Instance against George K. Young, contesting ownership and seeking to quiet title over a parcel of land located on Agho Island. Subsequently, on April 24, 1980, de Luzuriaga filed Civil Case No. 21-33C against Young for forcible entry, claiming that Young's representatives unlawfully dispossessed him from the property. Young contested this filing on multiple grounds, primarily asserting that jurisdiction over the forcible entry case was improper due to the ongoing ownership dispute in Civil Case No. 13336.
Jurisdictional Challenges
In his answer to the forcible entry suit, Young raised affirmative defenses, including lack of jurisdiction, the existence of a pending case involving the same parties and cause of action, and the violation of rules against multiplicity of suits. Instead of conducting a preliminary hearing as sought by Young, Judge Adil ordered him to submit a written Motion to Dismiss. Notably, despite not having received Young's memorandum, Judge Adil scheduled the trial for September 28, 1980, and subsequently denied Young's Motion to Dismiss.
Legal Reasoning and Decision
Respondent Judge Adil reasoned that since the act of dispossession alleged by de Luzuriaga was not included in Civil Case No. 13336, it raised doubts about the viability of the forcible entry case as an independent suit. The judge emphasized that the issues of possession and ownership were intertwined, thereby necessitating their consolidation into a single complaint to avoid conflicting judgments.
The Court affirmed Judge Adil’s decision, noting that allowing separate cases could lead to an abatement of one suit due to the other. Citing Sections 3 and 4 of Rule 2 of the Revised Rules of Court, the Court reiterated the principle that a party may institute only one suit for a single cause of action to prevent repeated litigation and unnecessary vexation fo
...continue readingCase Syllabus (G.R. No. L-58912)
Case Background
- This case involves an appeal from a decision made by Judge Midpantao L. Adil of the Court of First Instance of Iloilo.
- The appeal seeks to enjoin the presiding judge of the Municipal Circuit Court of Estancia, Iloilo from proceeding with the trial of Civil Case No. 21-33C, which involves a forcible entry claim filed by Roberto R. de Luzuriaga, Sr. against George K. Young.
- The crux of the dispute lies in the intertwined issues of possession and ownership of a parcel of land, specifically Lot No. 2 of Fp-9941 situated at Agho Island, Concepcion, Iloilo.
Parties Involved
- Petitioner: Roberto R. de Luzuriaga, Sr.
- Respondents: Hon. Midpantao L. Adil (Judge) and George K. Young (Defendant).
Legal Context
- The respondent, George K. Young, challenges the jurisdiction of the Municipal Circuit Court to hear Civil Case No. 21-33C, arguing that the matter of possession is intrinsically linked to ownership, which is already being contested in a separate action to quiet title pending in the Court of First Instance.
Factual Background
- George K. Young is the registered owner of the disputed lot, covered by Transfer Certificate of Title No. T-5455.
- On April 21, 1980, de Luzuriaga and others filed Civil Case No. 13336 in the Court of First Instance seeking to quiet title, annul deeds, and declare sole heirship or ownership, involving the same property.
- Three days later, on April 24, 1980, de Luzuriaga initiated Civil Case No. 21-33C for forcible entry against Young, claiming unlawful dispossession.