Case Summary (G.R. No. 254957-58)
Relevant Facts and Procedural History
Initially, Atty. Armando Galvez leased the apartment from the respondent at a monthly rate of P200. The petitioners commenced their residence there with Atty. Galvez in 1966, and they remained after his death on August 23, 1977. The private respondent sought to evict them, asserting that the lease was personal to Atty. Galvez and could not be inherited by the petitioners. The City Court of Manila ruled in favor of the petitioners, a decision later reversed by Judge Madela, which led to the current direct appeal by the petitioners, focusing on jurisdictional issues.
Legal Issues Presented
The primary legal issue pertains to whether the petitioners had the right to continue occupying the apartment after the lease between the private respondent and Atty. Galvez ended with the latter's death. The petitioners argued against the jurisdiction of the City Court to entertain the unlawful detainer action, claiming that such action required one year to be filed after the possession became unlawful. They contended that their possession was never unlawful prior to the death of Atty. Galvez.
Jurisdictional Arguments
The petitioners contended that the City Court lacked jurisdiction because the nature of the action was incapable of pecuniary estimation and should fall under the jurisdiction of the Court of First Instance. They emphasized that an action for unlawful detainer must be filed within one year from the moment possession becomes unlawful, which they argued only occurred after Atty. Galvez’s death.
Court's Analysis on Jurisdiction
In addressing the jurisdictional challenges presented by the petitioners, the court noted that the action was effectively an unlawful detainer action, which is subject to the exclusive jurisdiction of city or municipal courts, despite the complexities involving legal questions of lease inheritance. The court established that the unlawful nature of the petitioners' possession began on August 23, 1977, which was within the parameters allowed for
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Case Background
- This case revolves around an unlawful detainer action initiated by the private respondent, Pedro V. Malit, aimed at ejecting the petitioners, Warlito and Araceli Mabalot, from an apartment located at No. 2262 Coral Street, San Andres, Manila.
- The initial ruling by the City Court favored the petitioners, but this decision was subsequently appealed by Malit to the Court of First Instance of Manila.
- On January 6, 1981, Judge Tomas P. Madela, Jr. reversed the lower court's decision, ordering the petitioners to vacate the premises.
Legal Issues Raised
- The petitioners contested the jurisdiction of both the City Court of Manila and the Court of First Instance to hear the case, arguing that the action was improperly classified as unlawful detainer.
- They maintained that the subject matter of the case was incapable of pecuniary estimation, thereby falling under the jurisdiction of the Court of First Instance as per Section 44(a) of the former Judiciary Act.
Factual Summary
- The facts, as summarized in Judge Madela's decision, indicate that Atty. Armando Galvez leased the apartment to the private respondent at a monthly rate of P200 since 1967.
- Araceli Mabalot, who was ass