Facts:

The case titled Balagtas Realty Corporation vs. Hon. Manuel V. Romillo, Jr. involves a dispute between Balagtas Realty Corporation (the petitioner) and several respondents, including Judge Manuel V. Romillo, Jr., as well as private individuals Burt Raymond, Yu Chun Hian, Edward Finlan, Jack Lerner, Cornelius Breed, Marsha Baechler, Lourdes Ang, Victoria Teves, and Josephine Ting. The case originated from a series of ejectment actions filed by Balagtas Realty Corporation against the respondents, who were tenants of residential apartments located in Pasay City, on May 22, 1982. The Court of First Instance of Rizal in Pasay City initially ruled in favor of the petitioner, granting the immediate execution of an earlier judgment from the Pasay City Court in various Civil Cases. However, on December 21, 1982, Judge Romillo issued a ruling that reversed the previous decision, dismissing the ejectment complaints on the grounds of invalid demand letters and the unreasonableness of the re

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Facts:

Background of the Case

• The case involves two consolidated petitions brought by Balagtas Realty Corporation (petitioner) challenging the rulings of respondent Judge Manuel V. Romillo, Jr. in two separate sets of proceedings.
• The petitions arose from disputes over the increased rental payments demanded by the petitioner from private respondents who occupied apartment units in Pasay City.
• The petitioner, as the new owner and successor-in-interest of the Perez-Rubio Trust, sought to enforce a letter-contract (Exhibit “A”) dated April 21, 1976, which terminated the old month-to-month lease (at P750 per month) and offered a new lease at an increased rate of P2,000 per month (with a P1,000 discount for timely payment).

Chronology and Procedural History (Ejectment and Lease Dispute)

• An original petition for certiorari and prohibition (G.R. Nos. L-48376-85) was decided on May 22, 1982, setting aside a lower court’s order and directing the execution of a City Court judgment in various ejectment cases.
• The decision of the Pasay City Court was reversed on December 21, 1982 by the Court of First Instance of Rizal, Pasay City, Branch XXXVII, where the presiding Judge ruled to dismiss the complaints and modify the contractual obligations by crediting excess consignments to future rentals.
• The petitioner moved for reconsideration and the immediate issuance of writs of ejectment pursuant to the earlier Supreme Court ejectment order, but the respondent Judge denied such motions on February 11, 1983, holding that the execution of the judgment was untimely due to the already reversed lower court decision.
• Subsequently, the petitioner filed a supplemental petition for review, arguing that respondent Judge erred in his reliance on unadmitted evidence, rejection of Exhibit “A” as constituting an agreement, invalidation of the demand letters (Exhibits “E”), and in determining both the absence of liquidated damages and the unreasonableness of the increased rental.

Chronology and Procedural History (Certiorari Involving Dominga Mapa)

• In a consolidated petition (G.R. No. 63387) involving Dominga Mapa, the petitioner originally filed an action for unlawful detainer against her due to her failure to appear at a scheduled hearing and subsequent judgment by default awarding liquidated damages and rental arrears.
• Private respondent Dominga Mapa, invoking the defense of ownership, challenged the default judgment in a petition for certiorari before the Regional Trial Court.
• On November 15, 1982, respondent Judge dismissed Dominga Mapa’s petition on the grounds of failure to prosecute and the availability of a proper appeal remedy from a motion to set aside the default judgment.
• On February 11, 1983, respondent Judge reversed the dismissal and reinstated the petition without legal basis, prompting the petitioner to file the instant petition before the Supreme Court on the ground that the judge acted without jurisdiction and with arbitrariness.

Issue:

Whether the letter-contract (Exhibit “A”), which terminated the old month-to-month lease and imposed a new lease with increased rentals, constituted a valid and binding agreement between the parties.

• The issue centers on the alleged lack of a “meeting of the minds” concerning material terms under Articles 1319, 1320, and 1321 of the Civil Code.
• Whether the denial by respondent Judge of the contractual validity of Exhibit “A” was justified.

Whether the increased rental rate of P2,000 per month (with a discount option) imposed by the petitioner was reasonable, given that the previous rate was P750 per month.

• The central question is if an increase from P750 to P2,000 (an over 200% hike) can be upheld as reasonable and not unconscionable.
• This includes examining the admissibility and accuracy of evidence, particularly the appraisal report (Exhibit “112”) provided by the lessees' own real estate appraiser.

Whether the respondent Judge erred in relying on exhibits and evidence that were not admitted in the trial court or are inconsistent with the documentary record.

• Specific errors include reliance on private respondents’ exhibits not legally before the appellate court.
• Misapplication of the evidentiary rules regarding the letter-contract and demand letters.

Whether the award of liquidated damages (P4,000 per lessee) should be sustained.

• Whether there was a clear and express agreement by the lessees to pay liquidated damages under the terms set out in Exhibit “A”.

Whether the respondent Judge acted arbitrarily, capriciously, and with grave abuse of discretion by reversing the trial court’s findings on the reasonableness of the increased rent and by erroneously reinstating the petition for certiorari in Dominga Mapa’s case.

• The issue also encompasses whether the proper remedy (appeal) was bypassed in favor of certiorari.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)