G.R. No. 94733 - Municipality of Binan, Laguna vs. Court of Appeals

On September 27, 1989, the petitioner, the Municipality of Binan, Laguna, filed Civil Case No. 2473 for unlawful detainer in the Municipal Trial Court of Binan, Laguna.
The petitioner sought a writ of preliminary mandatory injunction against the private respondent, asserting that renewal of the existent 25‐year lease contract was no longer feasible due to the municipality’s pressing need for the premises to be used as national and provincial offices.

On October 5, 1989, the private respondent filed his answer, contending that the lease for the initial period had not yet expired and that he had exercised his exclusive option to renew the lease for another 25 years.
The petitioner filed its reply on October 9, 1989, and shortly thereafter, on October 16, 1989, the private respondent moved for a preliminary hearing as if a motion to dismiss, arguing that the complaint failed to state a cause of action based on the terms of the lease.

After the exchange of motions, replies, and position papers, the Municipal Trial Court rendered judgment on October 26, 1989, ordering the private respondent to vacate the premises.
Subsequently, on November 8, 1989, the private respondent filed a manifestation/motion requesting that the pending issues, particularly those raised in his motion for preliminary hearing, be resolved prior to entry of judgment.
Although the private respondent received a copy of the decision on November 10, 1989, he promptly filed a notice of appeal on November 20, 1989 at the Regional Trial Court of Laguna.

On December 5, 1989, the petitioner filed a motion for execution pending appeal before the Regional Trial Court.
On December 14, 1989, the presiding judge (Hon. Jose Mar. Garcia) of Branch 24 granted the petitioner’s motion for discretionary execution.
A writ of execution was subsequently issued on December 15, 1989, authorizing enforcement of the judgment.

On December 29, 1989, the private respondent filed a petition for certiorari with a prayer for a writ of preliminary injunction, contending that the trial court’s order allowing execution was issued without providing him the required copy of the motion for execution, in violation of Section 6, Rule 15 of the Rules of Court.
The Court of Appeals, in its judgment dated May 31, 1990, set aside the disputed order and annulled the judgment of the Municipal Trial Court in Civil Case No. 2473 on the ground that it was contrary to both Section 6, Rule 15 and the agreement between the parties.

The petitioner filed a motion for reconsideration, arguing that the Court of Appeals had exceeded its authority by addressing issues (i.e., the municipal trial court judgment) not raised in the petition for certiorari.
The private respondent countered that the merits of the municipal trial court judgment were adequately raised and controverted, and further emphasized the procedural rule that controversies should be resolved in a single proceeding to avoid multiplicity of suits.

Was the order authorizing the issuance of a writ of execution pending appeal valid, considering the requirement of Section 6, Rule 15 that mandates proof of prior notice to the adverse party before the court acts on a motion?
Did the trial court commit an abuse of discretion or exceed its jurisdiction by granting the motion for execution without proper notice?

Did the Court of Appeals act within its jurisdiction when it annulled the municipal trial court’s judgment in Civil Case No. 2473, which was still pending on appeal before the Regional Trial Court?
Is it proper for the Court of Appeals to rule on the merits of the main case when such issues were not raised in the petition for certiorari?

May issues regarding the sufficiency of the alleged cause of action (in particular, the controversy over the 25-year lease renewal) be decided in a petition for certiorari, or should they be reserved for ordinary appeal?
Does the conduct of the trial court in handling the preliminary hearing on the affirmative defense (lack of cause of action) fall within the ambit of correctable jurisdictional error or is it a matter for appeal on the merits?