G.R. No. L-1555; January 31, 1948
GREGORIO NICOMEDES, petitioner-appellant, vs. RAMON A. YCASIANO ET AL., respondent-appellees.

FACTS

Petitioner Gregorio Nicomedes sought to declare the Municipal Court of Manila without jurisdiction over a complaint filed against him by respondent Crispina de Leon. The complaint alleged that de Leon owned a building leased to Nicomedes on a month-to-month basis at P300 since February 1945; that on December 17, 1946, Nicomedes was notified the rent would increase to P400 starting January 1947; that Nicomedes failed to pay the increased rent and violated lease terms by not maintaining the premises; and that de Leon needed the property for her own use. Nicomedes argued the suit was not an unlawful detainer case because it sought to collect P400, not the originally agreed P300.

ISSUE

Whether the Municipal Court of Manila had jurisdiction over the complaint, i.e., whether the allegations constituted a case of unlawful detainer under Rule 72 of the Rules of Court.

RULING

Yes. The Supreme Court affirmed the lower court’s ruling that the Municipal Court had jurisdiction. The complaint contained the essential elements of unlawful detainer: (a) plaintiff’s ownership; (b) a contract of lease on a monthly basis; (c) notice to terminate the lease or pay increased rent; and (d) the tenant’s failure to comply and retention of possession. The prayer for ouster, rents, and damages was typical in detainer actions. The Court clarified that the tenant’s defense—that the demanded rent was not the originally agreed amount—pertained to the merits of the case, not to the municipal court’s jurisdiction. Jurisdiction over unlawful detainer cases is conferred by statute upon municipal or justice of the peace courts, and the complaint’s allegations sufficiently invoked that jurisdiction.

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