Case Digest (G.R. No. 195477) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Herminio E. Erorita and Editha C. Erorita (petitioners) versus Spouses Ligaya Dumlao and Antonio Dumlao (respondents), the latter acquired by extrajudicial foreclosure sale on April 25, 1990 a parcel of land in Barangay San Mariano, Roxas, Oriental Mindoro, covered by TCT No. T-53000, where the petitioners operated the San Mariano Academy. Although the respondents agreed to allow the petitioners to continue the school’s operation, they claimed a monthly rent of ₱20,000 remained unpaid since 1990, while the petitioners insisted they ran the school out of goodwill and friendship without rental obligations. On December 16, 2002, the respondents demanded that the petitioners vacate the property; the petitioners delayed closure pending a Department of Education clearance. On March 4, 2004, the respondents filed Civil Case No. C-492 for recovery of possession before the Regional Trial Court (RTC) against the petitioners and their administrators, Hernan and Susan Erorita. Th Case Digest (G.R. No. 195477) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Property and Parties
- Spouses Antonio and Ligaya Dumlao acquired a parcel of land in Barangay San Mariano, Roxas, Oriental Mindoro by extrajudicial foreclosure sale on April 25, 1990 (TCT No. T-53000).
- Former owners Spouses Herminio and Editha Erorita continued to operate San Mariano Academy on the property; Hernan and Susan Erorita were appointed as its administrators.
- Tenancy Arrangement and Demand to Vacate
- The Dumlaos alleged an oral lease at Twenty Thousand Pesos (P20,000.00) per month starting 1990; the Eroritas claimed the use was gratuitous, based on goodwill.
- On December 16, 2002, the Dumlaos demanded that the Eroritas vacate; full closure of the school was delayed pending Department of Education clearance.
- Proceedings in the Regional Trial Court (RTC)
- On March 4, 2004, the Dumlaos filed a complaint for recovery of possession with RTC (Civil Case No. C-492). The Eroritas failed to appear at pre-trial and were declared in default, leading to ex parte presentation of evidence.
- On June 4, 2007, the RTC ordered the Eroritas to vacate immediately, turn over possession, pay arrearages, damages, and attorney’s fees, and barred them from enrolling new students.
- Court of Appeals (CA) Ruling and Supreme Court Petition
- The Eroritas appealed; on July 28, 2010, the CA affirmed, holding that under Republic Act No. 7691 the RTC had jurisdiction (assessed value > P20,000.00) and treating the action as accion publiciana, not unlawful detainer.
- The CA denied the Eroritas’ motion for reconsideration on January 4, 2011. Spouses Erorita then filed a petition for review on certiorari with the Supreme Court.
Issues:
- Whether the RTC had jurisdiction over the complaint for recovery of possession.
- Whether Hernan and Susan Erorita were improperly impleaded as parties.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)