Facts:

In the case of Ismael Amorganda and Trinidad G. Amorganda v. Honorable Court of Appeals, Estanislao Saycon, and Clara Saycon [G.R. No. 80040, September 30, 1988], the petitioners, spouses Ismael and Trinidad Amorganda, entered into a lease agreement with private respondents, spouses Estanislao and Clara Saycon, on July 30, 1977, leasing a fishpond in Cabalulan, Manipis, Tanjay, Negros Oriental, for a period of ten years at an annual rental of P3,000. The lease was extended in 1981 for an additional two years and then again in 1982 for another eight years. The Saycons, however, harvested fish from the pond on January 5, 1986, without the consent of the Amorgandas, prompting the latter to file a criminal complaint for qualified theft. On February 27, 1986, the Saycons forcibly entered the fishpond and barred the petitioners and their workers from accessing it. Subsequently, the Amorgandas filed a civil complaint against the Saycons for recovery of possession and damages in the Reg

...

Facts:

Background and Lease Agreements

• The dispute arose from a fishpond lease contract between the parties:
• Petitioners: Ismael Amorganda and Trinidad G. Amorganda, who entered into a lease agreement.
• Respondents: Estanislao and Clara Saycon, the lessors and private respondents.
• Chronology of the Lease:
• On 30 July 1977, the lessors leased a fishpond at Cabalulan, Manipis, Tanjay, Negros Oriental to the petitioners for a period of ten (10) years.
• The lease involved a specific parcel of land, part of PLA No. 2086, in the name of Pedro Saycon, the lessors’ deceased father.
• The annual rental was fixed at P3,000.00, paid in advance for the entire lease period.
• Subsequent Extensions:
• On 30 January 1981, the lease period was extended for an additional two (2) years, set to expire on 30 July 1989, with rental payments duly received.
• On 20 December 1982, in consideration of another advance rental, the lease was further extended for eight (8) years, terminating on 31 July 1997.

Breach of Lease and Unauthorized Actions

• On 5 January 1986, the respondents harvested bangus and shrimps from the fishpond without the petitioners’ consent, prompting a criminal complaint for qualified theft filed by the petitioners.
• On 27 February 1986, the respondents allegedly, with the aid of armed men, entered the leased premises forcibly, thereby barring the petitioners and their workers from access.

Litigation Initiation and Relief Sought

• The petitioners instituted Civil Case No. 8794 in the Regional Trial Court to:
• Compel the return of possession of the fishpond.
• Claim damages for lost use, moral and exemplary damages, attorney’s fees, and other incidental expenses.
• Request a writ of preliminary injunction restraining the respondents from further interference.
• The Regional Trial Court issued a temporary restraining order on 4 March 1986 and subsequently a writ of preliminary injunction on 23 April 1986 upon the petitioners’ application and the filing of an injunction bond.

Respondents’ Defenses and Subsequent Appeals

• In their Answer filed on 26 March 1986, the respondents argued that:
• Estanislao Saycon was not the true owner of the leased property; the land reverted to the government after the cancellation of Pedro Saycon’s license.
• The petitioners had no valid right to the fishpond since it had been forfeited in favor of the government, which purportedly transferred jurisdiction to the Bureau of Fisheries and Aquatic Resources (BFAR).
• The proper venue for the recovery of possession was the Municipal Court of Tanjay, not the Regional Trial Court, due to the nature of the action.
• The petitioners failed to exhaust all available administrative remedies prior to resorting to judicial intervention.
• The respondents further petitioned the Intermediate Appellate Court (now the Court of Appeals) to annul the RTC’s injunction order and dismiss the civil case, contending jurisdictional defects and lack of cause of action.

Appellate Review and Motion for Reconsideration

• On 17 July 1987, the Court of Appeals declared the RTC’s order of 23 April 1986 null and void, dismissing Civil Case No. 8794 on jurisdictional grounds by classifying the case as a recovery of possession action.
• The petitioners, in response, filed a motion for reconsideration on 10 August 1987.
• The motion was filed two (2) calendar days past the reglementary deadline, as counsel argued a mistaken belief regarding the holiday status of the filing deadline.
• The respondents contended that such delay warranted denial of the motion.

Issue:

Timeliness of the Motion for Reconsideration

• Was the petitioners’ motion for reconsideration, filed on 10 August 1987, valid despite being two (2) calendar days late, considering the alleged misunderstanding about the holiday?
• Does a minor lapse in the filing period, absent any prejudice to the respondents, suffice to suspend strict adherence to procedural rules in favor of substantial justice?

Jurisdiction of the Regional Trial Court

• Does the Regional Trial Court of Negros Oriental have jurisdiction over the case, given that the respondents argued the action should have been filed in the Municipal Trial Court or before the BFAR?
• Is the central cause of action one for specific performance and damages under a lease contract, or is it merely a recovery of possession case, which would alter the proper venue and jurisdiction?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)