Title
Guzman vs. Guzman
Case
G.R. No. 172588
Decision Date
Mar 18, 2013
Petitioner sought ejectment of respondents; Supreme Court denied petition, citing improper remedy, finality of judgment, and limited scope of certiorari.

Case Digest (G.R. No. L-68288)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • On June 15, 2000, petitioner Isabel N. Guzman filed a complaint for ejectment with the Municipal Trial Court (MTC) of Tuguegarao City, Cagayan, Branch 4.
    • The complaint involved a dispute over a 1,446-square meter parcel of land (Lot No. 2419-B, under TCT No. T-74707) in Tuguegarao City, where petitioner and Arnold N. Guzman held fractional interests (6/7 and 1/7, respectively).
    • Respondents, Aniano N. Guzman and Primitiva G. Montealto (the petitioner’s children), were alleged to occupy the property by tolerance after refusing to vacate despite a written demand dated January 17, 2000.
    • Prior barangay conciliation proceedings failed to settle the dispute between the petitioner and respondents.
  • Contentions and Counterclaims
    • The petitioner maintained her claim on ownership and right to possession, asserting that the respondents held no independent possessory or ownership rights.
    • In their answer, the respondents countered by alleging that:
      • The petitioner had, through a document dated December 28, 1996, transferred all her property rights in the disputed property (except her usufructuary right) in favor of them.
      • The petitioner was engaging in forum shopping, as she had already raised a separate issue of ownership in a pending petition for cancellation of adverse claim at Branch 4 of the Regional Trial Court (RTC) of Tuguegarao City.
  • Proceedings at the Municipal Trial Court (MTC)
    • On November 27, 2002, the MTC ruled in favor of the petitioner by:
      • Declaring her the lawful owner with the right to possession of the property.
      • Holding that the respondents, as mere children to whom no possession flowed, had no vested rights over the land.
      • Dismissing the allegation of forum shopping, noting that the petitioner asserted ownership solely to establish her right of possession.
    • The court ordered:
      • The respondents to vacate the land and surrender possession to the petitioner.
      • Payment by the respondents of P5,000.00 as monthly rental (from January 2000 until possession was surrendered) and an additional P15,000.00 as moral and exemplary damages.
  • Proceedings at the Regional Trial Court (RTC)
    • The respondents appealed the MTC ruling to the RTC of Tuguegarao City, Branch 1. They argued, among other points, that:
      • The MTC lacked jurisdiction over the case.
      • The petitioner did not have a valid cause of action against the respondents.
      • The petitioner had engaged in forum shopping.
      • The MTC erred in ruling in the petitioner’s favor.
    • On May 19, 2005, the RTC:
      • Rejected the respondents’ arguments, affirming the MTC’s jurisdiction under Section 33(2) of Batas Pambansa Bilang 129 and the petitioner’s cause of action.
      • Ruled in favor of the respondents by emphasizing the petitioner’s prior transfer of rights, which the RTC held could not be unilaterally revoked without judicial intervention.
      • Noted that the petitioner had failed to allege and prove earnest efforts at compromise before filing the complaint.
    • Consequently, the RTC ordered the petitioner to pay the respondents P25,000.00 as attorney’s fees and an additional P25,000.00 for litigation expenses.
  • Petitioner’s Motions for Reconsideration and Subsequent Filing
    • After receiving a copy of the RTC decision on June 16, 2005, the petitioner filed three separate motions for reconsideration:
      • The first motion (filed on June 30, 2005) was denied due to the filing of the motion without the required notice of hearing.
      • The second motion (filed on July 14, 2005) was denied for being filed out of time, in accordance with Section 5, Rule 37 of the Rules of Court.
      • The third motion (filed on July 20, 2005) was denied with finality on July 22, 2005.
    • On August 8, 2005, the petitioner filed a Rule 65 petition for certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC on several grounds related to:
      • Addressing issues not raised as errors on appeal (e.g., transfer and revocation of rights).
      • Strict enforcement of the notice of hearing requirement for motions.
  • Proceedings at the Court of Appeals (CA)
    • On February 3, 2006, the CA dismissed the petitioner’s petition on the ground that:
      • The Rule 65 petition for certiorari was the wrong remedy for challenging an RTC decision rendered in its appellate jurisdiction; the correct remedy being a Rule 42 petition for review.
      • The petitioner had forfeited her chance to appeal by filing a second motion for reconsideration, a pleading prohibited by Section 5, Rule 37 of the Rules of Court.
    • The CA later denied the petitioner’s subsequent motion for reconsideration, leading to the current Rule 45 petition.

Issues:

  • Jurisprudential Issue Regarding the Remedy
    • Whether the petitioner’s filing of a Rule 65 petition for certiorari, in lieu of a proper Rule 42 petition for review, was a valid exercise of judicial remedy.
    • Whether the petitioner’s resort to multiple motions for reconsideration effectively forfeited her right to appeal by filing a second, prohibited motion under Section 5, Rule 37.
  • Issue on the Nature of Errors Raised
    • Whether the alleged errors—pertaining to the RTC’s appreciation of issues not raised on appeal (e.g., the transfer of rights and the strict notice of hearing requirement)—constituted reversible errors amounting to grave abuse of discretion.
    • Whether the RTC’s action in ruling on the petitioner’s claims, despite them not being raised on appeal, was within its appellate jurisdiction when assessing the entire record of the lower court proceedings.
  • Finality and Immutability of the RTC Decision
    • Whether the RTC decision, having become final and executory, can be modified even if errors of judgment are alleged.
    • The impact of the petitioner’s procedural mistakes on her ability to resurrect a lost appeal through a Rule 65 petition for certiorari.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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