People vs. Magdowa, 73 Phil. 512

Case No.: G.R. No.
L-44353
Case Title: Martha Feranil and Primitivo Villegas vs. Hon. Gumersindo Arcilla, in his capacity as Presiding
Judge, Branch III, City Court of Davao City and Spouses Alfonso Cardenas and Lolita Cardenas
Date: February 28, 1979
Short Summary of Facts:

Martha Feranil and Primitivo Villegas, the petitioners, filed an ejectment case (Civil Case No. 2727-C of the
City Court of Davao City) against Spouses Alfonso and Lolita Cardenas, the respondents, on October 3, 1975.
The plaintiffs sought a preliminary mandatory injunction, which was granted. The defendants, in their answer,
raised affirmative defenses including lack of cause of action and capacity to sue of Villegas. The City Court
modified the injunction, dropped Villegas from the complaint, and later dissolved the injunction for lack of a
bond. Petitioners appealed the decision of the City Court to the Court of First Instance of Davao, which upheld
the City Court's decision.
Issues:
A. Whether the dropping of Villegas from the complaint was proper.
B. Whether the dissolution of the preliminary mandatory injunction was justified.
C. Whether the order for removal of improvements introduced after the injunction but before trial was valid.
Ruling and Decision:

1. The dropping of Villegas from the complaint was deemed improper as it failed to consider Villegas' valid
cause of action for unlawful detainer based on a lease contract. The court highlighted that the designation of
the complaint does not dictate the cause of action; rather, it's the allegations within the complaint that define it.
Thus, Villegas should have been reinstated as a plaintiff.
2. The dissolution of the preliminary mandatory injunction was found to be without factual or legal basis since
Villegas, who signed the bond, was improperly dropped from the complaint. With Villegas reinstated, the bond
remained valid, and the injunction should be restored.
3. The order for removal of improvements introduced after the injunction but before trial was declared without
effect. The court emphasized the purpose of a mandatory injunction, which is to restore the plaintiffs to their
possession as if the illegal act never occurred. Therefore, the order to remove improvements was inconsistent
with the purpose of the injunction.
Doctrine Highlighted:
The court emphasized the principle that the real cause of action in a complaint is determined by the allegations
within the body of the complaint, not by its designation or caption. This underscores the importance of
analyzing the substance of the allegations to ascertain the legal basis of a claim. Furthermore, the decision
highlights the differing effects of prohibitory and mandatory injunctions, with the latter aiming to restore the
status quo to the situation before the illegal act occurred.
In this case, the designation of the offense as "Forcible Entry, Damages, with Preliminary Mandatory
Injunction" was initially used by the parties, the City Court, and the respondent judge to define the nature of the
complaint. However, the court pointed out that while this designation may indicate the perceived nature of the
case, it does not necessarily determine the actual cause of action presented in the complaint.
The relevance of the designation of offense lies in how it influenced the interpretation of the complaint by both
the City Court and the respondent judge. They focused solely on the label "Forcible Entry" and failed to
recognize that the complaint contained allegations that could also support a case of unlawful detainer.
The court emphasized that the designation or caption of the complaint is not controlling; rather, it is the
allegations within the body of the complaint that define the cause of action. Therefore, the designation of
offense, while it may provide some indication of the legal basis of the case, should not override the substantive
allegations presented in the complaint. This highlights the importance of looking beyond the title of a case and
examining the actual factual and legal contentions put forth by the parties.

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Case No.: G.R. No.

Short Summary of Facts:

Ruling and Decision:

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