G.R. No. 257675 - People vs. Ramos y Garcia

Balagtas Realty Corporation, the petitioner, is the owner of a row of residential apartments in Pasay City, and it initiated legal action against various private respondents for illegal detainer and non-payment of rentals.
On May 11, 1976, the petitioner filed nineteen identical complaints for illegal detainer against the respondents for their failure to vacate the leased apartment premises and to pay rental arrears, as well as to pay an increased monthly rental of P2,000.00 effective May 1, 1976, notwithstanding a formal demand.

The separate complaints were consolidated and heard jointly in Branch IV of the Pasay City Court, under the supervision of City Judge Francisco R. Llamas.
On January 25, 1977, Judge Llamas rendered judgment in eleven of these cases (the remaining cases having been terminated earlier).
The dispositive portion of the judgment ordered each respondent to:

The detailed computation of rental arrears, along with corresponding case numbers and apartment designations, was provided.

On January 26, 1977, the petitioner filed separate motions for immediate execution of the judgment under Section 8, Rule 70 of the Revised Rules of Court.
In response, ten private respondents filed a common notice of appeal on February 10, 1977, each posting a supersedeas bond covering:

The City Court approved these bonds, stayed the immediate execution, and subsequently elevated the cases to the Court of First Instance of Rizal (Branch XXVII), presided over by Judge Manuel V. Romillo, Jr.

On October 11, 1977, the petitioner filed for the second time separate motions for immediate ejectment execution based on respondents’ failure to deposit the monthly rentals (P2,000.00 per month) on time from February 1977 to September 1977.
The respondents, however, contended that they had made deposits as required, relying on contractual provisions.
A discrepancy arose regarding the proper amount of the monthly rental:

The dispositive portion of the City Court’s decision clearly stated that each respondent was to pay P2,000.00 monthly.
Some respondents, notably Burt Raymond and Lourdes Lukban Ang, argued based on a Letter-Contract of April 21, 1976 that a discount was available if rental was paid within the first three days of the month, effectively reducing the timely payment to P1,000.00.
Other respondents maintained that while the judgment fixed P2,000.00 as the current rental, the interpretation of the discount provision should allow for a lower deposit if payments were effected within the prescribed period.

On March 30, 1978, Judge Romillo denied the petitioner’s motions for immediate ejectment execution, noting that the records supported the respondents’ claims of timely deposit, at least in part.

The petitioner, alleging that the order of Judge Romillo was a patent nullity, instituted the present petition for certiorari and prohibition.
The petition sought:

A reversal of the March 30, 1978 order denying immediate ejectment execution.
A determination on whether the respondents’ alleged failure to deposit the full P2,000.00 monthly rental on time constituted abandonment of their appeal.

The petition raised issues relating to the correct interpretation and application of Section 8, Rule 70 of the Revised Rules of Court, especially in reference to the mandatory nature of the deposit requirement.

Whether or not Judge Romillo acted without and/or in excess of his jurisdiction and/or abused his discretion in denying the petitioner’s motions for immediate ejectment execution.

Whether the failure of the respondents to deposit the full monthly rental of P2,000.00 on or before the tenth day of each succeeding month constitutes a ground for immediate execution.
Whether such non-compliance indicates insincerity or an abandonment of their right to appeal.

Whether the execution of the judgment, based on the lack of full rental deposit, would constitute a bar to the respondents’ pending appeals.