Case Digest (G.R. No. 237201)
Facts:
Maria Victoria A. Reyes v. Isabel Mendoza Manalo, Celso Mendoza, Josephine Gonzales, Isagani Blanco, and All Persons Acting for and in Their Behalf, G.R. No. 237201, September 22, 2020, First Division, Peralta, C.J., writing for the Court.Petitioner Maria Victoria A. Reyes (Victoria) filed a Complaint for unlawful detainer on September 2, 2014, as a co-owner and descendant of the registered owners of a 19,735 sq. m. parcel covered by TCT No. J-7757 (T-1120) in Pinamalayan, Oriental Mindoro. Victoria alleged that her grandparents and later her family tolerated various occupants on the property and that respondents — Isabel Mendoza Manalo, Celso Mendoza, Josephine Gonzales, and Isagani Blanco — occupied specific portions without permission; she demanded possession and served letters in April and July 2014. The MTC denied her prayer for injunctive relief; respondents answered 33 days late. Victoria moved for judgment due to the belated answers, and the MTC rendered judgment for plaintiff on November 10, 2014, ordering defendants to vacate, remove structures, and pay attorney’s fees and costs.
The Regional Trial Court (RTC), Branch 41, Pinamalayan, affirmed the MTC in a July 6, 2015 Decision, agreeing the MTC properly acted under the summary nature of unlawful detainer. On appeal, the Court of Appeals (CA), however, in a Decision dated February 13, 2017, set aside both lower-court rulings. The CA found the controversy implicated ownership and not merely possession de facto; it held that the case should be tried as an accion reivindicatoria or otherwise as a plenary action cognizable by the RTC, and remanded the case for further proceedings. The CA denied reconsideration in its January 11, 2018 Resolution.
Victoria filed a petition for review on certiorari under Rule 45 seeking to nullify the CA Decision and Resolution, arguing that the CA erred in admitting respondents’ belated Answers (filed 33 days after summons) in violation of Section 6, Rule 70 of the Rules of Court and that the t...(Pro-only)
Issues:
- Did the Court of Appeals err in reversing the MTC and RTC and admitting respondents’ Answers that were filed 33 days after service of summons (procedural question of relaxing the rules)?
- Did the Court of Appeals err in admitting respondents’ Answers in violation of Section 6, Rule 70 of the Rules of Court when the Answers contained no explanation for late filing (procedural forfeiture/waiver issue)?
- Was the controversy merely an unlawful detainer/ejectment cognizable by the MTC, or does it require a plenary action for recovery of possession...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)