Case Digest (G.R. No. 146364) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In June 1979, petitioner Colito T. Pajuyo paid P400 to a certain Pedro Perez for the rights over a 250-square-meter lot in Barrio Payatas, Quezon City, upon which he erected a light-materials house and occupied it with his family until December 7, 1985. On December 8, 1985, Pajuyo and private respondent Eddie Guevarra executed a Kasunduan whereby Pajuyo permitted Guevarra to reside in the house and lot rent-free, on condition that Guevarra maintain its cleanliness and orderliness and voluntarily vacate upon demand. In September 1994, Pajuyo demanded Guevarra’s vacatur; Guevarra refused, prompting Pajuyo to file an ejectment suit (Civil Case No. 12432) in the Metropolitan Trial Court (Branch 31) of Quezon City.On December 15, 1995, the MTC rendered judgment for Pajuyo, ordering Guevarra to vacate, pay P300 monthly compensation from the last demand, P3,000 attorney’s fees, and costs. Guevarra appealed to the Regional Trial Court (Branch 81), which on November 11, 1996 affirmed
Case Digest (G.R. No. 146364) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Acquisition and Occupancy
- In June 1979, Colito T. Pajuyo paid ₱400 to Pedro Perez for rights over a 250 sqm lot in Barrio Payatas, Quezon City, and constructed a light-materials house.
- Pajuyo and family occupied the house from 1979 until 7 December 1985.
- Kasunduan (8 December 1985)
- Pajuyo (owner of house and lot) allowed Eddie Guevarra to reside rent-free, on condition he maintain cleanliness and order and vacate on demand.
- In September 1994, Pajuyo demanded vacation; Guevarra refused.
- Judicial Proceedings
- MTC (15 December 1995): Granted ejectment; ordered Guevarra to vacate, pay ₱300 monthly rent from last demand, ₱3,000 attorney’s fees, and costs.
- RTC (11 November 1996): Affirmed MTC decision in toto.
- Guevarra filed motion for extension to file petition for review (Rule 42); CA granted 30-day extension and reversed RTC (21 June 2000), declaring both parties squatters and the Kasunduan a commodatum.
- CA denied Pajuyo’s motion for reconsideration (14 December 2000).
- Supreme Court: Granted Pajuyo’s petition; set aside CA decisions; reinstated RTC, deleted attorney’s fees award, upheld ₱300 monthly rent from 16 February 1995.
Issues:
- Procedural
- Whether the CA erred in granting a 30-day extension when the RTC decision was already final and executory.
- Whether the CA erred in giving due course to the petition for review despite the certificate against forum-shopping being signed by counsel, not the party.
- Substantive
- Whether the Kasunduan is a commodatum (as held by CA) or a contract akin to lease (as held by lower courts).
- Whether the CA erred in applying the pari delicto principle and declaring both parties squatters.
- Whether the CA erred in resolving the ejectment case based on Proclamation No. 137 and the National Government Center Housing Project Code instead of the Kasunduan.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)