Pelaez v. Reyes
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from an unlawful detainer case filed by Rodulfo N. Pelaez against Honorata and Virginia Salazar. The core of the controversy lies in the appeal process following an adverse decision by the City Court of Cagayan de Oro City. While the parties generally agree that the issue of ownership was raised in the pleadings, they disagree on the proper venue for the appeal: the respondents contend it should be the Court of Appeals due to the ownership issue, while the petitioner argues it should remain with the Court of First Instance. 2. Procedural History: After the City Court of Cagayan de Oro City ruled against the Salazars in the unlawful detainer case, they filed a notice of appeal intended for the Court of Appeals. However, the City Court forwarded the case to the Court of First Instance. The Salazars insisted their appeal belonged to the Court of Appeals, while Pelaez moved to dismiss the appeal in the Court of First Instance as untimely. The Court of First Instance initially ruled it had no appellate jurisdiction but later reversed itself and took cognizance of the appeal. Consequently, the Salazars filed a petition for certiorari, prohibition, and mandamus with the Court of Appeals, seeking to nullify the Court of First Instance's order. The Court of Appeals gave due course to this petition and issued a writ of preliminary injunction, enjoining both the City Court and the Court of First Instance from proceeding with the case. 3. The Petition: Rodulfo N. Pelaez filed the instant petition for prohibition with the Supreme Court, seeking to declare the Court of Appeals without jurisdiction to hear the Salazars' petition. Pelaez argued that the appeal from the City Court's decision in the unlawful detainer case, even with an ownership issue, should have been directed to the Court of First Instance, not the Court of Appeals. He contended that the City Court's resolution of ownership was merely in conjunction with possession and did not alter the nature of the case as an unlawful detainer suit. The Supreme Court, however, found that the City Court had concurrent jurisdiction over ejectment cases where ownership is an issue, and therefore, the appeal was correctly lodged with the Court of Appeals.
Issue(s)
Whether the Court of Appeals has jurisdiction to entertain a petition for certiorari, prohibition, and mandamus concerning the appellate jurisdiction of the Court of First Instance in an unlawful detainer case appealed from a city court where the issue of ownership is involved. Whether an appeal from a city court's decision in an unlawful detainer case, where the issue of ownership is raised in the pleadings, should be filed with the Court of First Instance or the Court of Appeals.
Ruling
The petition is dismissed. The Court of Appeals should declare the petition in CA-G.R. No. SP-07900 moot and academic and dismiss the same. The Court of First Instance of Misamis Oriental should desist from taking cognizance of the appeal and order the return of the records to the court of origin, allowing the City Court of Cagayan de Oro City to act on the record on appeal and give due course to the appeal to the Court of Appeals.
Ratio Decidendi
On the jurisdiction of the Court of Appeals and the proper appellate court: The Supreme Court held that the issue of where the appeal should lie was a matter of settling the property allocation of appellate jurisdiction, which the Supreme Court has the exclusive prerogative to settle. The Court found that the issue of ownership was indeed involved in the unlawful detainer case, as evidenced by the pleadings and trial evidence presented by both parties. Citing Section 3 of Republic Act No. 5967, which amended Section 88 of the Judiciary Act, the Court affirmed that city courts have concurrent original jurisdiction with the Court of First Instance over ejectment cases where the question of ownership is brought in issue in the pleadings. The Court clarified that the phrase "in conjunction with the issue of possession" means that both issues are to be resolved by the city court. Therefore, when ownership is an issue, the appeal from the city court's decision should be to the Court of Appeals, not the Court of First Instance. The Court also noted that the petition before the CA was not premature, despite the petitioner's impatience, because the matter of appellate jurisdiction was a significant legal question that needed resolution. On the nature of the issue of ownership in unlawful detainer cases: The Court found that the pleadings and evidence presented clearly showed that the issue of ownership was raised. The defendants' answer denied the plaintiff's claim of ownership and asserted ownership by Delfina Javier, the mother of one of the defendants. During the trial, further evidence was presented, including a confirmation of transfer of rights and ownership from Delfina Javier to her daughter, Virginia Salazar. The Court applied Section 5, Rule 10 of the Rules of Court, stating that even if the pleadings were not formally amended, the issue of ownership, having been tried by implied consent of the parties, should be treated as if it were properly raised. This meant that the city court had the authority to resolve the ownership issue concurrently with the possession issue, as granted by R.A. 5967.
Main Doctrine
In ejectment cases originating from a city court where the issue of ownership is raised in the pleadings, the appeal from the city court's decision lies with the Court of Appeals, not the Court of First Instance, as the city court exercises concurrent original jurisdiction with the Court of First Instance over such cases.