Case Summary (G.R. No. 47184)
Facts of the Case
Petitioner Vicente Romey initiated a legal action in the municipal court to recover a monetary amount from respondent Dionisio Saddie. In response, Saddie filed a cross-complaint, claiming unpaid rent on a house he had leased to Romey and sought to have Romey vacate the premises. The municipal court ultimately dismissed Romey’s complaint and granted Saddie’s cross-complaint, ordering Romey to pay the owed rent and vacate the house.
Appeal and Jurisdictional Issues
Romey was notified of the municipal court's judgment on November 18, 1939, and filed his appeal on November 29, 1939. Respondent Saddie subsequently moved for the execution of the judgment based on an assertion that Romey had failed to perfect his appeal in the required time frame. The Court of First Instance found that the appeal for the dismissal of Romey’s complaint was timely, but the appeal concerning the cross-complaint was not because it involved an illegal detainer that should have been appealed within ten days.
Legal Characterization of the Cross-Complaint
Romey contended that the municipal court lacked jurisdiction to entertain Saddie’s cross-complaint because it was not adequately alleged that Romey had failed to meet the terms of the lease within the requisite timeframe. However, the evidence showed that Saddie’s cross-complaint was indeed filed after a demand had been made. The court noted that the cross-complaint was incorrectly termed a counterclaim since a counterclaim typically seeks monetary compensation only, while a cross-complaint seeks other forms of relief, such as eviction.
Court's holding on Jurisdiction
The decision indicated that inferior courts like the municipal court routinely lack the power to adjudicate cross-complaints, thereby rendered Saddie’s pleading invalid. The ruling further elaborated that allowing such a cross-complaint could provoke procedural anomalies, such as requiring Romey to file separate appeals based on multiple claims encompassed in a single judgment.
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Case Overview
- Vicente Romey, the petitioner, initiated an action in the municipal court of Manila seeking to recover PHP 148 from Dionisio Saddie, one of the respondents.
- Saddie countered by filing a cross-complaint, claiming rental payments for a house leased to Romey and seeking an order for Romey to vacate the premises.
- The municipal court ruled in favor of Saddie, dismissing Romey's complaint and ordering him to pay the unpaid rentals and vacate the house.
Procedural History
- Romey was notified of the municipal court's judgment on November 18, 1939.
- He perfected his appeal on November 29, 1939, eleven days after notification.
- Upon reaching the Court of First Instance of Manila, Saddie filed a motion for execution of the judgment regarding the cross-complaint, arguing that Romey’s appeal was not perfected within the required ten days.
Court of First Instance Ruling
- The Court of First Instance determined that Romey's appeal was timely concerning the dismissal of his complaint for money but untimely regarding the cross-complaint, which pertained to illegal detainer requiring a ten-day appeal period.
- Consequently, the court ordered the execution of the judgment related to the cross-complaint.
Petitioner’s Arguments
- Romey contended that the municipal court lacked jurisdiction over the cross-complaint for illegal detainer because there was no allegation of his failure to comply