Title
Soledad vs. Mamangun
Case
G.R. No. L-17983
Decision Date
May 30, 1963
Landlord sued tenant for unpaid rent; tenant contested jurisdiction, but court allowed amended complaint, ruling in landlord's favor, upheld on appeal.

Case Summary (G.R. No. 94523)

Initial Proceedings

Soledad initiated legal action in the Municipal Court of Manila to recover unpaid rentals at the rate of P180.00 per month. The complaint requested that Mamangun vacate the leased premises. During the proceedings, Mamangun filed a motion to dismiss, arguing that the court lacked jurisdiction due to the absence of an allegation regarding illegal withholding of possession. He pointed out that the amount sought by Soledad exceeded P2,000.00, suggesting that the Municipal Court could not adjudicate the matter.

Amended Complaint

In response to the motion to dismiss, Soledad filed an amended complaint including necessary allegations to address Mamangun's concerns. Mamangun opposed the admission of this amended complaint, claiming that the court lacked jurisdiction over the initial complaint and consequently could not validly act on the amended complaint.

Trial Court's Rulings

The Municipal Court denied Mamangun's motion to dismiss as well as his opposition to the amended complaint, allowing Soledad to proceed with presenting evidence. Mamangun chose not to participate in the subsequent hearings, maintaining his stance that the court lacked jurisdiction. The court rendered judgment in favor of Soledad, ordering Mamangun to vacate the premises and pay P2,520.00 in unpaid rentals, in addition to a specified sum for attorney's fees.

Appeal to the Court of First Instance

Mamangun appealed the decision to the Court of First Instance, reiterating his jurisdictional arguments. The court again denied his motion to dismiss. After filing his answer, which restated his jurisdictional defense, Mamangun pursued a certiorari petition to this Court, which was dismissed on June 9, 1959, for lack of merit. Subsequently, the case was submitted based solely on the pleadings, leading to a judgment once more in favor of Soledad.

Appellate Court's Analysis

On appeal, Mamangun argued that the original complaint should have been dismissed due to jurisdictional issues, specifically contending that the action was improperly characterized and that the amount claimed exceeded the Municipal Court's jurisdiction. The appellate court evaluated whether Soledad's right to amend the complaint, as allowed by the relevant rules, was appropriately exercised.

Conclusion on Jurisdiction and Amendment Rights

The appellate court ruled that Soledad had the right to amend his com

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