Case Digest (G.R. No. 214782) Core Legal Reasoning Model
Facts:
This case arises from a petition for review filed by National Transmission Corporation (TransCo) against Bermuda Development Corporation (BDC). The events began on December 22, 2009, when BDC filed a case for unlawful detainer against TransCo at the Municipal Trial Court (MTC) of Cabuyao, Laguna, labeled Civil Case No. 2498. TransCo responded on January 23, 2009, by submitting an answer along with an affirmative and compulsory counterclaim. After due proceedings, the MTC issued a decision on August 24, 2009, ordering TransCo to vacate Lot 10-B, which is an 8,920-square meter property in Barangay Banlic, Cabuyao, Laguna. The decision also mandated TransCo to pay BDC Php 10,350,000.00 for unpaid rental going back to December 13, 2008, attorney’s fees, and other costs.
TransCo appealed the MTC decision to the Regional Trial Court (RTC) of Biñan, Laguna on September 17, 2009. Meanwhile, BDC filed an Urgent Motion for Execution of the MTC's decision, which the RTC granted on Oct
... Case Digest (G.R. No. 214782) Expanded Legal Reasoning Model
Facts:
- Unlawful Detainer and Initial Proceedings
- On December 22, 2009, Bermuda Development Corporation (BDC) filed a case for unlawful detainer against National Transmission Corporation (TransCo) before the Municipal Trial Court (MTC) of Cabuyao, docketed as Civil Case No. 2498.
- On January 23, 2009, TransCo filed its Answer, which contained both affirmative and compulsory counterclaims.
- The MTC rendered its decision on August 24, 2009, ordering TransCo:
- To vacate the subject lot (Lot 10-B, Psd. 043404-058243, 8,920 square meters located at Barangay Banlic, Cabuyao, Laguna) and remove all structures thereon.
- To pay BDC a computed rental in the amount of ₱10,350,000.00 from December 13, 2008, until full vacation of the premises.
- To pay additional costs including attorney’s fees and court appearance fees.
- Appeals, Motions for Execution, and Garnishment
- On September 17, 2009, TransCo appealed the MTC decision before the Regional Trial Court (RTC), Branch 24, of BiAan, Laguna.
- BDC filed an Urgent Motion for Execution of the MTC decision, which was granted by RTC, Branch 24 on October 28, 2009, resulting in the issuance of a Writ of Execution.
- Following this, on November 6, 2009, the RTC issued a Notice of Garnishment against TransCo’s account with Land Bank of the Philippines.
- On November 10, 2009, TransCo filed an Omnibus Motion seeking:
- Reconsideration of the RTC’s October 28, 2009 order.
- Quashing of the writ of execution and the notice of garnishment.
- Expropriation Proceedings
- On January 21, 2010, TransCo filed a Complaint for Expropriation concerning the subject property (covered by TCT No. 258244) before RTC, eventually heard by Branch 25 as Civil Case B-7972.
- On February 25, 2010, TransCo filed an urgent ex-parte motion before RTC Branch 25 for the issuance of a Writ of Possession. To support its motion, TransCo deposited ₱10,704,000.00 with Landbank, purportedly as the provisional value of the property.
- RTC, Branch 25 then issued an Order granting the writ on March 29, 2010.
- Dismissal of the Unlawful Detainer Appeal and Subsequent Developments
- On July 29, 2010, RTC, Branch 24 dismissed TransCo’s appeal in the unlawful detainer case as “moot and academic,” noting that:
- TransCo had initiated expropriation proceedings, effectively abandoning its appeal.
- Possession of the property had already been delivered formally.
- TransCo’s appeal dismissal led to ordering the enforcement of judgment on rental in arrears.
- A motion for reconsideration was subsequently filed by TransCo but was denied on May 30, 2011, by RTC, Branch 24.
- The Court of Appeals (CA) then affirmed the RTC orders in its Decision dated May 29, 2014 and denied further reconsideration on October 7, 2014.
- National Transmission Corporation (TransCo) finally petitioned for review under Rule 45 of the Rules of Court.
Issues:
- Whether the RTC erred in dismissing TransCo’s appeal on the ground that the case had become “moot and academic” due to the filing of expropriation proceedings for the same property.
- Whether a case for recovery of possession (or ejectment) against a public service corporation—endowed with the power of eminent domain—can prosper, or if the proper remedy is solely the recovery of just compensation and consequential damages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)