Romey v. Roxas
REITERATIONFacts
1. The Antecedents: Petitioner Vicente Romey initiated a case in the municipal court of Manila seeking to recover P148 from respondent Dionisio Saddie. In response, Saddie filed a pleading designated as a counterclaim, demanding unpaid rents and seeking an order for Romey to vacate the leased premises. 2. Procedural History: The municipal court ruled in favor of Saddie, dismissing Romey's complaint and ordering Romey to pay rentals and vacate the property. Romey was notified on November 18, 1939, and perfected his appeal eleven days later, on November 29, 1939. In the Court of First Instance, Saddie moved for execution of the judgment on the cross-complaint, arguing the appeal was untimely. The Court of First Instance found the appeal timely for the dismissal of the complaint but untimely for the cross-complaint (illegal detainer), ordering execution of the latter. 3. The Petition: This petition for certiorari challenges the Court of First Instance's order for execution. Petitioner argues the municipal court lacked jurisdiction over the cross-complaint for illegal detainer due to the absence of a required jurisdictional allegation regarding demand and failure to comply within five days. The Supreme Court considered whether the municipal court had the authority to entertain a cross-complaint, concluding that inferior courts have limited jurisdiction and cannot entertain cross-complaints unless expressly provided by law, rendering the municipal court's judgment on the illegal detainer aspect void.
Issue(s)
Whether the municipal court had jurisdiction to entertain the cross-complaint for illegal detainer. Whether the appeal from the municipal court's judgment was perfected within the reglementary period for both the complaint and the cross-complaint. Whether the Court of First Instance had jurisdiction to order the execution of the municipal court's judgment on the cross-complaint.
Ruling
The petition for certiorari is granted. The order of execution issued by the Court of First Instance of Manila is set aside. The judgment of the municipal court with respect to illegal detainer is declared null and void. The petitioner's appeal is declared to have been perfected in time and may take its due course.
Ratio Decidendi
On the jurisdiction of inferior courts over cross-complaints: The Court held that inferior courts have limited jurisdiction and cannot entertain cross-complaints, as there is no statutory provision authorizing them to do so. A counterclaim is a claim for money, while a cross-complaint seeks relief other than payment of money. In this case, the respondent's pleading, which sought to have the plaintiff vacate the premises, was a cross-complaint, not a counterclaim. The Court reiterated the principle that the provisions governing procedure in Courts of First Instance are not applicable in inferior courts unless expressly provided by law, and that inferior courts' jurisdiction cannot be extended by implication. Allowing a cross-complaint in an inferior court would lead to anomalous situations, such as requiring separate appeals from different portions of a single judgment, with different time limits and procedural requirements, which is not contemplated by law. On the timeliness of the appeal: The Court found that the municipal court's judgment concerning the claim for rentals was valid, as it was in the nature of a counterclaim. However, the judgment regarding illegal detainer was null and void for lack of jurisdiction. Consequently, the time for perfecting an appeal from the valid portion of the judgment (rentals) was fifteen days, as it was an ordinary action. The appeal was perfected within this period. Since there was legally no judgment for illegal detainer, the appeal from that portion was not subject to the ten-day period applicable to summary actions for illegal detainer. On the jurisdiction of the Court of First Instance to order execution: Because the judgment of the municipal court concerning illegal detainer was null and void, the Court of First Instance had no jurisdiction to order the execution of that portion of the judgment. Similarly, it had no jurisdiction to order the monthly deposits required by law for illegal detainer cases. The appeal from the valid portion of the judgment was perfected in time, and thus, the CFI should not have ordered execution pending appeal.
Main Doctrine
Inferior courts do not have the power to entertain cross-complaints, as their jurisdiction is limited and cannot be extended by implication. A pleading seeking relief other than payment of money constitutes a cross-complaint, not a counterclaim.