Title
Barrazona vs. Regional Trial Court, Branch 61, Baguio City
Case
G.R. No. 154282
Decision Date
Apr 7, 2006
A tenant defaulted on rent, prompting a landlord to file a collection case. The Supreme Court ruled it was an ejectment case, annulling the RTC's decision for lack of jurisdiction.

Case Digest (G.R. No. 154282)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Petitioner: Vangie Barrazona, who had been leasing premises in a building owned by San-an Realty and Development Corporation.
    • Respondents:
      • Regional Trial Court (RTC), Branch 61, Baguio City.
      • San-an Realty and Development Corporation, represented by Rodrigo Chua Tiu.
    • Lease Agreement:
      • Subject Property: Parts of a building located at Naguilian corner Asin Road, Baguio City (Units 203 A and 203 B on the second floor).
      • Lease Term: Two (2) years, commencing July 15, 2001 and ending June 30, 2003.
      • Rental Rate: P400.00 per square meter for Unit 203 A and P500.00 per square meter for Unit 203 B.
  • Payment Default and Litigation Initiation
    • Default in Rental Payments:
      • Beginning in August 2001, petitioner defaulted in her monthly rental payments.
      • Despite repeated demands by the respondent, the arrears were not settled.
    • Filing of Complaint by Respondent:
      • Date: May 14, 2002.
      • Nature of Complaint: "Collection of Sum of Money with Damages" (Civil Case No. 5238-R).
      • Allegations included non-payment of rentals and demands for vacating the leased premises.
  • Motion to Dismiss and Jurisdictional Argument
    • Petitioner's Motion to Dismiss:
      • Date Filed: June 3, 2002, with the RTC.
      • Grounds Claimed:
        • The RTC lacked jurisdiction because the allegations in the complaint indicated an ejectment (illegal detainer) action, which falls under the exclusive jurisdiction of the Municipal Trial Court (MTC).
        • Specific reference to paragraphs 4 and 5 of the complaint that highlighted:
          • Non-payment of rentals (starting from August 2001).
ii. Demand for payment of an overdue amount and instruction to vacate the premises.
  • RTC’s Order on the Motion:
    • Date of Order: June 19, 2002.
    • Decision: Denied petitioner's Motion to Dismiss for lack of merit.
  • Petition for Certiorari
    • Grounds Raised by the Petitioner:
      • Allegation that the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying her Motion to Dismiss.
      • Contention that the RTC Resolution was unconstitutional by failing to state the factual and legal basis for its decision.
    • Respondent’s Counterarguments:
      • The complaint’s primary allegation was for the collection of unpaid rentals – not an ejectment – with no intent to evict petitioner.
      • Petitioner's failure to file a motion for reconsideration prior to resorting to certiorari.
      • The RTC order being interlocutory and therefore not immediately appealable.
  • Supreme Court’s Intervention
    • Jurisdictional Analysis:
      • Emphasis on Section 1, Rule 16 of the 1997 Rules of Civil Procedure, which allows a motion to dismiss on the ground of lack of jurisdiction when based on the complaint’s allegations.
      • Reference to the principle that the nature of the action is determined by the complaint’s statements, where the inclusion of a demand to vacate indicated an ejectment action under the MTC’s jurisdiction.
    • Evaluation of RTC’s Order:
      • The RTC failed to provide a detailed reasoning as mandated by Section 3, Rule 16 of the Rules, thereby rendering the order vague and insufficient.
    • Remedy and Exception to Motion for Reconsideration:
      • The Court ruled that certiorari was an appropriate remedy given the grave abuse of discretion and the statutory exception allowing bypassing a motion for reconsideration in cases involving jurisdictional nullity or urgent judicial intervention.

Issues:

  • Jurisdictional Appropriateness
    • Whether the RTC had proper jurisdiction over the complaint given that the allegations effectively presented an ejectment action, which should be filed before the Municipal Trial Court (MTC).
  • Sufficiency of the RTC Resolution
    • Whether the RTC’s Order denying the Motion to Dismiss, by failing to clearly state its legal basis and reasoning, violated constitutional and procedural mandates.
  • Procedural Prerequisite for Certiorari
    • Whether the petitioner was required to file a motion for reconsideration before resorting to a petition for certiorari under the circumstances of an evident jurisdictional error and grave abuse of discretion.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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