Case Summary (G.R. No. L-2926)
Jurisdictional Authority of Courts
- The case involves an action to collect P2,000, which is not a foreclosure suit.
- The mortgage copy attached to the complaint does not indicate that the original has been registered with the Register of Deeds.
- The Justice of the Peace Court of Imus, Cavite, holds exclusive original jurisdiction over the case due to the amount involved and the residency of both parties.
- The Court of First Instance of Cavite lacked jurisdiction to hear the case, rendering its dismissal of the complaint void and without legal effect.
Background of the Mortgage Agreement
- On December 20, 1944, Paz S. Jarin, Felicisima A. Palma, and Trinidad Palma paid Daniel Sarinas P25,000 in exchange for a mortgage on a property in Imus, Cavite.
- The mortgage included the lot, a house, and other improvements, secured by Torrens Transfer Certificate of Title No. 11641.
- The agreement stipulated that if the mortgagor paid the P25,000 and the interest from five mango trees within two years, the mortgage would be discharged.
- On January 20, 1945, the mortgagor acknowledged receipt of an additional P25,000, with the same property as security.
- On February 19, 1945, the mortgagor acknowledged receipt of P50,000 in Japanese military notes and agreed to pay P2,000 in genuine currency at the end of the original mortgage term.
Dispute Over Debt Payment
- The debtors claimed that the P50,000 in Japanese military notes had no value and refused to pay the stipulated P2,000 despite demands from the creditors.
- On August 7, 1948, the creditors initiated legal action to collect the P2,000, lawful interest, and costs.
- The defendants filed a motion to dismiss the complaint, citing Executive Order No. 25, as amended by Executive Order No. 32, which suspended debt payments.
- The initial motion to dismiss was denied, but upon reconsideration, the court dismissed the complaint, stating that the facts did not constitute a cause of action.
Legal Arguments and Constitutional Issues
- The appellants argued that Republic Act No. 342 lifted the suspension of payments for both pre-war debts and those incurred during enemy occupation.
- The constitutionality of Executive Orders Nos. 25 and 32 was questioned, with claims that they violated constitutional limitations on legislative power regarding contract obligations.
- At the time of the action, Republic Act No. 296, known as the Judiciary Act of 1948, was in effect, which de...continue reading