Title
Regulus Development, Inc. vs. Dela Cruz
Case
G.R. No. 198172
Decision Date
Jan 25, 2016
A landlord seeks to evict a tenant who refuses to vacate the premises despite the termination of their lease agreement, leading to a legal battle over jurisdiction and the right to levy on the tenant's property.
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Case Digest (G.R. No. 198172)

Facts:

  • Regulus Development, Inc. (petitioner) owns the San Juan Apartments in Pasay City.
  • Antonio dela Cruz (respondent) leased two units (Unit 2002-A and Unit 2002-B) in 1993 and 1994, respectively.
  • Lease agreements specified a one-month lease period, subject to automatic renewals unless terminated by written notice.
  • Petitioner sent a termination letter, but respondent refused to vacate the premises.
  • Petitioner filed an ejectment complaint on May 1, 2001, before the Metropolitan Trial Court (MTC) of Pasay City.
  • MTC ruled in favor of the petitioner, ordering the respondent to vacate and pay due rentals.
  • Respondent appealed to the Regional Trial Court (RTC), which affirmed the MTC's decision.
  • Due to the petitioner's refusal to accept the monthly rentals, the respondent consigned them to the RTC.
  • The Court of Appeals (CA) later reversed the lower courts' decisions and dismissed the ejectment case, which became final on March 19, 2003.
  • Petitioner filed motions to withdraw the consigned rentals, which the RTC granted.
  • Respondent's motion for reconsideration was denied, and the RTC issued a writ of execution.
  • Respondent's petition for certiorari to the CA was dismissed, and the Supreme Court upheld the RTC's orders.
  • Petitioner moved for the issuance of a writ of execution to levy on the respondent's property to satisfy the judgment credit.
  • RTC granted this motion, but the CA later ruled that the RTC had no jurisdiction to levy on the respondent's real property, ordering the case to be remanded to the MTC for execution.
  • Petitioner challenged this CA ruling before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  1. Yes, the RTC had jurisdiction to levy on the respondent's real property.
  2. No, the lack of a notarial seal on the Verification and Certification against Forum Shopping was not fatal to the petition.
  3. ...(Unlock)

Ratio:

  • The Supreme Court granted the petition, reversing the CA's decision and reinstating the RTC's orders.
  • The lack of a notarial seal on the Verification and Certification against Forum Shopping was a procedural defect that did not render the petition fatally defective.
  • The CA correctly refused to dismiss the petition as it substantially complied with the requirements.
  • The issue of jurisdiction prevented the case from becoming moot an...continue reading

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