Case Digest (G.R. No. 83959)
Facts:
Ruperto de Guzman v. The Honorable Court of Appeals (Special Fifteenth Division) and Dr. Fortunato V. Correa, G.R. No. 83959, April 08, 1991, Supreme Court First Division, Medialdea, J., writing for the Court.
Petitioner Ruperto de Guzman was a tenant under a written lease of a rice mill and warehouse in Angat, Bulacan, originally with the late Teodora Villarama, mother of respondent Dr. Fortunato V. Correa. The written lease expired on April 29, 1975; petitioner allegedly continued on a month-to-month basis but defaulted in rent for May and June 1977. Respondent demanded surrender of the premises and thereafter filed an ejectment case (Civil Case No. 183) in the Municipal Trial Court (MTC) of Angat; the MTC rendered judgment for respondent on June 29, 1978, and declared it final and executory on December 28, 1978.
Petitioner sought relief in the Court of First Instance (now Regional Trial Court, RTC) by filing Special Civil Action No. SM-960 (captioned variously as certiorari/prohibition/mandamus and later treated as petition for contempt with restraining order), challenging the MTC proceedings in Civil Case No. 183. A restraining order issued; the RTC ultimately declared the MTC proceedings in Civil Case No. 183 null and void and dismissed the case for lack of the requisite demand under Section 2, Rule 70, Rules of Court.
Respondent then filed a second ejectment action in the MTC, Civil Case No. 286. The MTC, in a decision dated October 16, 1984, ordered petitioner to vacate, to pay monthly rental of P175.00 from May 1977 until vacatur with 14% interest, and awarded P10,000.00 moral damages, P5,000.00 exemplary damages, P5,000.00 attorney’s fees and costs. Petitioner filed petitions and restraining motions in SM-960 (which by then had been reassigned to RTC, Branch 16, Malolos), and the RTC issued a temporary restraining order; Civil Case No. 286 was appealed to the RTC as Civil Case No. 7903-M and raffled to the same branch.
On April 11, 1986 the RTC, Branch 16 (Judge Gualberto J. dela Llana), affirmed the MTC decision in Civil Case No. 286. Petitioner’s motion for reconsideration was denied, and he then brought a petition for certiorari, prohibition and mandamus to the Court of Appeals asserting grave abuse of discretion and jurisdictional defects, including litis pendencia and lack of cause of action. The Court of Appeals, Special Fifteenth Division, dismissed the petition for lack of merit in a decision dated May 11, 1988, and denied petitioner’s motion for...(Pro-only)
Issues:
- Was the Court of Appeals correct in holding that the dismissal of the first ejectment case in SM-960 for lack of demand under Section 2, Rule 70 did not bar the second ejectment case (i.e., is litis pendencia inapplicable)?
- Did respondent have a valid cause of action for ejectment and unpaid rentals despite the original lease being with the deceased lessor (i.e., was the lease terminated by the lessor’s death and did respondent’s Torrens title support his claim)?
- Were the awards of moral and exemplary damages and attorney’s fees proper in an ejectment action, and wa...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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