Aguilar v. Cabrera
REITERATIONFacts
The Antecedents: Rafael Flameno executed a deed of absolute sale in favor of Celestino Aguilar for a parcel of land with buildings for P57,000. The sale was registered, and a transfer certificate of title was issued to Aguilar. Simultaneously, a contract of lease was executed, wherein Flameno would occupy the premises for thirty days free of charge, followed by an additional sixty days with a P150 monthly rental, after which he was to vacate. The ninety-day period expired on January 16, 1944, but Flameno refused to vacate despite demands. Procedural History: Aguilar filed an unlawful detainer case against Flameno in the Municipal Court of Manila. Flameno answered, alleging the deed of sale and lease contract were fictitious and simulated, and that the true agreement was a mortgage. He also filed a separate action in the Court of First Instance to annul these contracts and declare the transaction a mortgage. The respondent judge, upon submission of memorandums, dismissed the case, rejecting an amended complaint, on the grounds that Aguilar admitted not being in possession, that ownership was involved, that damages claimed were beyond the municipal court's jurisdiction, and that the amended complaint changed the action's nature. The Petition: Aguilar filed a petition for mandamus to compel the respondent judge to hear and decide the unlawful detainer case on the merits.
Issue(s)
Whether mandamus lies to compel the respondent judge to hear and decide the case on the merits. Whether the respondent judge has jurisdiction to hear and decide the unlawful detainer case on the merits, notwithstanding the defendant's claim of ownership and the pendency of an action to annul the sale and lease contracts.
Ruling
The Court ruled in favor of the petitioner, ordering the issuance of the writ of mandamus. The respondent judge was directed to hear and decide the unlawful detainer case on the merits.
Ratio Decidendi
On the issue of whether mandamus lies: The Court held that mandamus is the proper remedy when a judge erroneously believes he has no jurisdiction and refuses to perform an imperative duty enjoined by law. An appeal would not be a plain, speedy, and adequate remedy, as it would entail unnecessary delay and expense. The Court emphasized that if the case is indeed one of unlawful detainer, the law specifically requires the municipal court to hear and decide it on the merits, and refusal to do so constitutes an unlawful neglect of duty. The fact that an appeal may lie does not prevent mandamus if the judge refuses to perform a duty. On the issue of jurisdiction over the unlawful detainer case: The Court reiterated the principle that to determine jurisdiction in ejectment cases, the averments of the complaint and the character of the relief sought must be primarily considered, not the allegations in the answer. The plaintiff's complaint alleged unlawful detainer based on a lease agreement and prayed for ejectment and damages, not a declaration of ownership. The Court stated that a defendant cannot defeat an ejectment action merely by inserting a claim of ownership in his answer. The municipal court's jurisdiction is determined from the form of the complaint, not the answer's allegations. Therefore, the respondent judge erred in dismissing the case based on the defendant's claim of ownership and the pending action in the Court of First Instance. The judge may hear the evidence and dismiss the complaint if not proven, but not for lack of jurisdiction. The claim for damages was deemed accessory to the main action and permissible in an unlawful detainer case.
Main Doctrine
A municipal court has jurisdiction to hear and decide an unlawful detainer case on the merits, even if the defendant claims ownership of the premises, as the court must primarily consider the allegations and prayer of the complaint, not the allegations in the answer, to determine the nature of the action. The claim of ownership in the answer does not divest the municipal court of its jurisdiction over the ejectment case.