G.R. No. 226467 - People vs. X X X

Private respondent filed an ejectment case before the Municipal Trial Court in Cities (MTCC) of Iloilo City (Branch 1), docketed as Civil Case No. 332(93).
Petitioners, involved in a separate action for specific performance (Civil Case No. 21142), moved to hold in abeyance the preliminary conference in the ejectment suit until the specific performance case was decided.

The MTCC, acting on petitioners’ motion, initially suspended proceedings by delaying the preliminary conference to avoid inconsistency between the two cases.
Private respondent appealed from the MTCC order, which was assigned to the Regional Trial Court (RTC) of Iloilo City (Branch 34).
Petitioners filed a motion to dismiss the appeal on the ground that the challenged order was interlocutory; the RTC (Branch 34) denied the motion in its Order dated January 27, 1995.
A subsequent motion for reconsideration by petitioners was similarly denied on March 24, 1995.

Private respondent filed a Motion to Resume Proceedings before the RTC. On August 30, 1995, the RTC (Branch 34) granted the motion and directed the remand of the case records to the MTCC (Branch 1) for continued proceedings.
Petitioners filed a motion for reconsideration and clarification of the RTC’s August 30 Order, which was denied on October 17, 1995.
Petitioners subsequently brought the case before the Supreme Court by filing a petition for review (docketed as SP No. 39403) alleging grave abuse of discretion, essentially questioning whether the RTC acted without or in excess of jurisdiction in denying the dismissal of an appeal on an interlocutory order and in ordering the resumption of proceedings at the MTCC.

A temporary restraining order was issued on October 20, 1995, enjoining further proceedings in Civil Case No. 21713, though it later lapsed.
The MTCC eventually resumed proceedings despite the pending petition for review and after denying petitioners’ motion to hold proceedings in abeyance (Orders dated February 14, 1996, and March 1, 1996).
A supplemental petition for review was later filed by petitioners, adding the issue of whether the MTCC erred in resuming the ejectment suit despite the pending petition.

Whether or not the respondent RTC (Branch 34) gravely abused its discretion when it denied petitioners’ motion to dismiss an appeal from an interlocutory order.

The contention centers on the application of the rule that interlocutory orders are not ordinarily appealable.
Petitioners argue that allowing such an appeal contravenes the very objective of summary proceedings.

Whether or not the respondent RTC (Branch 34) gravely abused its discretion when it granted the Motion to Resume Proceedings and ordered the remand of the records to the MTCC (Branch 1).

Petitioners question the propriety of the RTC’s action, arguing that it indirectly affected the expeditious disposition of the ejectment case.
The issue involves whether the RTC should have refrained from restarting the proceedings in light of the pending petition for review.

Whether or not the respondent MTCC (Branch 1) erred in resuming the ejectment proceedings despite the timely filing of the petition for review.

This issue examines if resuming the proceedings undermines the remedial purpose behind the summary procedure rules designed for speedy resolution.
It also considers whether the circumstances warrant an exception similar to those found in the Vda. de Legaspi and Wilmon decisions.