Title
Bardelas vs. Rodriguez
Case
G.R. No. L-38467
Decision Date
Jun 28, 1974
Tenants challenged ejectment suit over unpaid rent; Supreme Court upheld validity, ruling laws cited by tenants inapplicable, dismissing appeal.
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Case Digest (G.R. No. L-38467)

Facts:

  1. Parties Involved:

    • Petitioners-Appellants: Catalina Bardelas, Tomas Nazarie, Juliana Domingo, Jose Encabo, Serapio Garcia, Juan Javier, Jose Mallari, Sotero Montoya, Emilia Olatan, Sesinando Pamaran, Arsenio San Pedro, Hilaria Tobias, Modesto Camino, Juan Umakyat, their respective families, and John Does.
    • Respondents-Defendants-Appellees: Hon. Antonio E. Rodriguez (Municipal Judge of Las Piñas, Rizal) and spouses Paz Basa Andres.
  2. Nature of the Case:

    • The case originated from an ejectment suit filed by Paz Basa Andres and Idelfonso Borbon against the petitioners in the Municipal Court of Las Piñas, Rizal (Civil Case No. 370). The suit was based on the petitioners' failure to pay rentals for the parcels of land they leased from the plaintiffs.
  3. Motions to Dismiss:

    • On September 15, 1970, the petitioners filed a motion to dismiss the complaint on three grounds:
      • The action was barred under Republic Act No. 267, as amended by Republic Act No. 498, and related municipal resolutions.
      • The named defendants were not trustees, guardians, or agents who could be sued for the benefit of "John Does."
      • The named defendants did not share a common interest or privity in the subject matter of the suit.
    • On September 16, 1970, defendant Jose Encabo filed a separate motion to dismiss, arguing that the plaintiff lacked legal capacity to sue and that the complaint failed to state a cause of action.
  4. Municipal Court's Decision:

    • The Municipal Court denied both motions to dismiss. Idelfonso Borbon was dropped from the case for lack of legal personality to sue. The defendants were ordered to answer the complaint.
  5. Subsequent Proceedings:

    • On August 10, 1971, the petitioners filed a Memorandum with Motion, invoking Republic Act No. 6126, which prohibited rent increases and ejectment for certain tenants. The Municipal Court denied the motion and set the case for hearing on the merits.
    • The petitioners then filed a petition for certiorari, mandamus, and prohibition with the Court of First Instance of Rizal (Civil Case No. 15532), which dismissed the petition and lifted a previously issued restraining order.
  6. Appeal to the Court of Appeals:

    • The petitioners appealed to the Court of Appeals, assigning errors in the Court of First Instance's dismissal of their petition. The Court of Appeals certified the case to the Supreme Court, as it involved purely legal issues.

Issue:

The sole issue presented for determination is whether the Court of First Instance of Rizal acted with grave abuse of discretion in dismissing the petition for certiorari, mandamus, and prohibition based on the pleadings filed in Civil Case No. 15532.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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