Case Digest (G.R. No. 84330) Core Legal Reasoning Model
Facts:
The case involved Ramon Y. Ascue as the petitioner and the Hon. Court of Appeals (8th Division), along with private respondents Ramón Antonio, Salvador Salenga, and Ulipia Fernandez. The events leading to this petition began on July 25, 1986, when the private respondents filed a complaint with the Metropolitan Trial Court of Manila, Branch 29. They alleged that they were lessees occupying certain premises owned by Ascue, with varying monthly rents of P635.00, P950.00, and P950.00 respectively. The respondents claimed that they had accumulated back rentals for the months of May, June, and July 1986, totaling P5,625.00, which Ascue had refused to collect, except for a partial payment from Antonio.
In response, Ascue filed a motion to dismiss the complaint, asserting that the Metropolitan Trial Court did not have jurisdiction over consignation cases because these are incapable of pecuniary estimation, which typically falls under the jurisdiction of the Regional Trial Court. Howeve
Case Digest (G.R. No. 84330) Expanded Legal Reasoning Model
Facts:
- Lease Agreement and Non-Payment of Rentals
- Private respondents Salvador Salenga, Ramon Antonio, and Ulipia Fernandez were lessees of petitioner Ramon Y. Ascue, occupying premises on Pepin St., Sampaloc, Manila.
- Their monthly rentals were P635.00, P950.00, and P950.00, respectively.
- Petitioner refused to collect rentals for May, June, and July 1986, except for P1,500.00 collected from respondent Antonio for May and half of June 1986.
- The total unpaid rentals amounted to P5,625.00, which private respondents sought to consign with the Metropolitan Trial Court (MeTC) of Manila, Branch 29.
- Motion to Dismiss
- Petitioner filed a motion to dismiss the complaint, arguing that consignation cases fall under the jurisdiction of the Regional Trial Court (RTC), not the MeTC, as the subject matter is incapable of pecuniary estimation.
- The MeTC denied the motion, ruling that the amount consigned (P5,625.00) was within its jurisdiction (below P20,000.00) and that a motion to dismiss is a prohibited pleading.
- Appeal to the RTC
- Petitioner appealed the MeTC's order to the RTC of Manila, Branch 52.
- The RTC dismissed the appeal as premature and held that the proper remedy was a special civil action for certiorari.
- Direct Appeal to the Supreme Court
- Petitioner filed a direct appeal to the Supreme Court (G.R. No. 78438), which referred the case to the Court of Appeals (CA) due to concurrent jurisdiction.
- The CA dismissed the petition, affirming the RTC's decision.
- Petition for Review on Certiorari
- Petitioner filed a petition for review on certiorari (G.R. No. 84330) with the Supreme Court, challenging the CA's decision.
Issues:
- Whether the Metropolitan Trial Court has jurisdiction over consignation cases where the amount consigned is below P20,000.00.
- Whether the proper remedy for the denial of a motion to dismiss based on lack of jurisdiction is an appeal or a special civil action for certiorari.
- Whether the Court of Appeals erred in issuing its decision despite pending incidents before the Supreme Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)