Case Digest (G.R. No. 119337)
Facts:
The case involves Bayview Hotel, Inc. (petitioner) and Club Filipino, Inc. de Cebu (respondent). On May 27, 1959, the petitioner entered into a lease agreement with the respondent for a parcel of land in Cebu City, allowing the petitioner to construct and operate a hotel complex known as the Magellan International Hotel for a duration of thirty years. The lease stipulated that upon expiration, ownership of the building and any permanent improvements would transfer to the respondent. The agreement also provided an option for the petitioner to renew the lease for an additional ten years, with rent calculated at five percent of the approved value of the land and improvements.
As the lease was set to expire on December 31, 1992, the petitioner notified the respondent of its intention to extend the lease under different terms. However, the respondent's Board of Directors insisted on adhering to the original lease provisions, leading to a breakdown in negotiations. Consequent...
Case Digest (G.R. No. 119337)
Facts:
Lease Agreement: On May 27, 1959, Bayview Hotel, Inc. (petitioner) entered into a 30-year lease agreement with Club Filipino, Inc. de Cebu (private respondent) for a parcel of land in Cebu City. The agreement allowed petitioner to construct and operate the Magellan International Hotel. Ownership of the building and improvements would transfer to private respondent upon lease expiration. Petitioner had the option to renew the lease for an additional 10 years at a rent of 5% of the approved value of the land and improvements.
Renewal Dispute: Before the lease expired on December 31, 1992, petitioner sought to extend the lease under different terms, but private respondent insisted on adhering to the original contract. Private respondent sent a notice to vacate and demanded payment of accrued rentals, claiming ownership of the building and improvements under the original agreement.
Ejectment Case: On May 18, 1993, private respondent filed an ejectment case against petitioner in the Metropolitan Trial Court (MTC) of Cebu, seeking recovery of accrued rentals amounting to P2,850,000.00 as of April 30, 1993, and P712,500.00 monthly thereafter.
Fire Incident: Before petitioner could be served with the complaint and summons, the building was destroyed by a fire of undetermined origin on May 21, 1993.
Petitioner’s Defense: Petitioner filed an answer to the ejectment complaint, raising affirmative defenses, including lack of jurisdiction due to improper service of summons, extinguishment of the claim due to the fire, and mootness of the ejectment case. Petitioner also moved for a preliminary hearing on its affirmative defenses, which the MTC denied.
Certiorari Petition: Petitioner filed a petition for certiorari with the Regional Trial Court (RTC) of Cebu, alleging abuse of discretion by the MTC judge. The RTC granted the petition and dismissed the ejectment case.
Appeal to Court of Appeals: Private respondent appealed to the Court of Appeals (CA), which reversed the RTC decision. The CA ruled that:
- Petitioner submitted to the MTC’s jurisdiction by seeking affirmative relief.
- The MTC retained jurisdiction despite the fire.
- The issue of possession was a factual matter for the MTC to resolve.
- The petition for certiorari was prohibited under the Revised Rules on Summary Procedure.
Issue:
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Ruling:
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Ratio:
Jurisdiction in Ejectment Cases: Jurisdiction in ejectment cases is determined by the nature of the action, which is the recovery of possession. The destruction of the building does not automatically extinguish the lessor-lessee relationship if the lessee continues to occupy the land.
Summary Procedure Rules: The Revised Rules on Summary Procedure are designed to ensure the expeditious resolution of ejectment cases. Prohibiting preliminary hearings on affirmative defenses and petitions for certiorari prevents delays and promotes judicial efficiency.
Prohibited Pleadings: Section 19 of the Revised Rules on Summary Procedure explicitly prohibits petitions for certiorari, mandamus, or prohibition against interlocutory orders. This prohibition is clear and must be strictly followed.