G.R. No. L-33157 - Lopez vs. Court of Appeals

Case Digest (G.R. No. L-33157)
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Facts:

Parties and subject of the case

Petitioners Jose Lee and Felix Lim sought certiorari and mandamus to set aside and annul the rulings in ejectment/unlawful detainer proceedings involving a leased commercial lot and building owned by private respondents Spouses Roy Po Lam and Josefa Po Lam.
Respondent trial court was the Municipal Trial Court of Legazpi City, Branch I.
Respondent appellate court was the Intermediate Appellate Court.
The complaint in the trial court was docketed as Civil Case No. 2687, entitled “Spouses ROY PO LAM and JOSEFA PO LAM, plaintiff, versus JOSE LEE, defendant; FELIX LIM, Intervenor.”

Filing of the complaint and allegations

On September 2, 1981, private respondents filed a complaint for ejectment and/or unlawful detainer against Jose Lee in the then City Court of Legazpi, Branch III, docketed as Civil Case No. 2687.
The complaint alleged that an oral contract of lease between private respondents and Jose Lee over a commercial lot and building owned by private respondents had already expired, and Jose Lee refused to vacate despite demands.
Private respondents prayed that judgment require Jose Lee to vacate the premises and to pay accrued monthly rentals, attorney’s fees, expenses, and exemplary damages.

Defendant’s answer and ownership issue

On September 7, 1981, Jose Lee filed an answer specifically denying private respondents’ allegation of ownership.
The denial was anchored on a final decision rendered by the then Court of Appeals on March 11, 1981 in CA-G.R. No. 44770.
That Court of Appeals decision declared Felix Lim owner of a portion of the property in question and entitled to exercise the right of redemption over the remaining portion from the subsequent buyer who was the predecessor-in-interest of private respondents.

Intervention by Felix Lim and additional ownership/redemption claims

On November 12, 1981, Felix Lim filed an answer in intervention in Civil Case No. 2687, which the trial court admitted.
Felix Lim claimed he was the declared owner of a portion and redemptioner of the rest by virtue of the March 11, 1981 Court of Appeals decision.
Felix Lim questioned the right of private respondents to receive rentals.

Felix Lim’s separate cases in the Court of First Instance of Albay

On November 3, 1981, prior to the intervention, Felix Lim filed a complaint in the then Court of First Instance of Albay, docketed as Civil Case No. 6696, questioning private respondents’ ownership and possession of the same property.
On February 9, 1982, Felix Lim filed another complaint in the Court of First Instance of Albay for reconveyance and annulment of sale and title, docketed as Civil Case No. 6767.

Transfer of the ejectment case due to inhibition and pre-trial motions

The presiding judge of the City Court of Legazpi, Branch III, where Civil Case No. 2687 was pending, inhibited himself.
The case was transferred to Branch I, now Branch I of the Municipal Trial Court of Legazpi City, presided by the respondent trial judge.
Before the merits hearing began, Jose Lee moved to suspend proceedings until final decision in Civil Cases Nos. 6697 and 6767 pending before the Court of First Instance of Albay.
The trial court denied Jose Lee’s motion in an order dated June 29, 1982.

Motions to dismiss for lack of jurisdiction raised by the intervenor

Felix Lim moved to dismiss Civil Case No. 2687, arguing the City Court/Municipal Trial Court had no jurisdiction over the nature and subject matter because ownership was involved.
The trial court denied the motion on June 29, 1982.
On August 29, 1982, Felix Lim reiterated the motion to dismiss, insisting that jurisdiction over the ownership issue belonged to the Court of First Instance of Albay in Civil Cases Nos. 6696 and 6767, whose resolution had been reserved while the ejectment case proceeded to trial.

Decision in the trial court

On December 19, 1983, respondent trial judge rendered a decision.
The trial judge ruled that the Municipal Trial Court of Legazpi City had jurisdiction over the issue of ownership in Civil Case No. 2687.
The dispositive portion declared plaintiffs lawful owners entitled to immediate possession of the leased commercial building and lot (lot 1557, covered by TCT No. 8102 formerly TCT 2580, as described in the complaint).
The court ordered defendant and anyone acting in his behalf to vacate and restore actual possession to the plaintiffs.
The court ordered payment of rentals accruing from October 1982 up to vacating, at P2,500.00 per month, minus amounts already deposited with the City Treasurer of Legazpi, retained for withdrawal by plaintiffs and their counsel or representative.
The court awarded P2,500.00 as exemplary damages and P1,200.00 as attorney’s fees, plus costs of the suit.
The intervenor’s claim and prayer were denied for lack of merit.

Appeal to the Inter...(Subscriber-Only)

Issues:

Jurisdiction of the trial court over ejectment where ownership was raised

Whether the Municipal Trial Court of Legazpi City had jurisdiction to decide the ownership issue in Civil Case No. 2687 for ejectment and/or unlawful detainer.

Whether the trial judge’s declaration of lawful ownership and related orders amounted to action without or in excess of jurisdiction, or grave abuse of discretion amounting to lack of jurisdiction.

Proper appellate procedure and the Intermediate Appellate Court’s action

Whether the Intermediate Appellate Court erred in dismissing the appeal instead of certifying the case to the proper court (...(Subscriber-Only)

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

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