Case Digest (G.R. No. 214241) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Ramon and Ligaya Gonzales v. Marmaine Realty Corporation, G.R. No. 214241, decided on December 5, 2016 under the 1987 Constitution, petitioners-Spouses Ramon and Ligaya Gonzales filed on October 30, 1997 before the Provincial Adjudicator (PARAD), DARAB Region IV, a Complaint for Recognition as Tenant with Damages and Temporary Restraining Order against respondent Marmaine Realty Corporation, represented by Mariano Manalo. Marmaine initially moved to dismiss and thereafter answered with a counterclaim, triggering trial. On January 6, 1998, the PARAD granted a writ of preliminary injunction in favor of petitioners, prompting them to annotate a Notice of Lis Pendens on respondent’s certificates of title on September 26, 2000. After trial, the PARAD dismissed the tenancy complaint by Decision dated June 27, 2002, and denied petitioners’ motion for reconsideration on August 7, 2002. The DARAB affirmed that decision on October 17, 2008, and its denial of reconsideration on ... Case Digest (G.R. No. 214241) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Proceedings in the Tenancy Case before the DARAB
- On October 30, 1997, Spouses Ramon and Ligaya Gonzales (Sps. Gonzales) filed a Complaint for Recognition as Tenant with Damages and Temporary Restraining Order against Marmaine Realty Corporation (Marmaine) before the Provincial Adjudicator, DARAB Region IV.
- Marmaine filed a Motion to Dismiss, seasonably answered with a Counterclaim, and trial ensued. On January 6, 1998, the PARAD issued a Resolution granting a writ of preliminary injunction in favor of Sps. Gonzales, prompting them to annotate a Notice of Lis Pendens on Marmaine’s titles on September 26, 2000.
- On June 27, 2002, the PARAD rendered a Decision dismissing the complaint for lack of merit; its August 7, 2002 Order denied reconsideration. Sps. Gonzales appealed to the DARAB, which on October 17, 2008 affirmed the PARAD Decision. A March 23, 2009 DARAB Resolution denied reconsideration, and the Decision became final and executory on May 7, 2009 (Entry of Judgment issued January 19, 2012).
- Motion to cancel the Notice of Lis Pendens and subsequent remedies
- On January 31, 2012, Marmaine moved for cancellation of the Notice of Lis Pendens. The PARAD initially denied the motion in a May 15, 2012 Order as premature, citing a pending civil case (RTC Branch 87, Civil Case No. RY2K-052).
- Upon reconsideration, the PARAD on December 4, 2012 set aside its earlier Order and directed the Register of Deeds to cancel the lis pendens, limiting the cancellation to the Tenancy Case. A January 22, 2013 motion for reconsideration was denied on October 16, 2013.
- Sps. Gonzales then filed a petition for review under Rule 43 with the Court of Appeals (CA) on December 13, 2013. The CA dismissed it on April 24, 2014 for non-exhaustion of administrative remedies and denied reconsideration on September 10, 2014. Sps. Gonzales subsequently filed this petition for review on certiorari before the Supreme Court.
Issues:
- Whether the CA erred in dismissing the petition for review on the ground of non-exhaustion of administrative remedies.
- Whether the PARAD correctly ordered the cancellation of the Notice of Lis Pendens annotated on Marmaine’s certificates of title.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)