Facts:

The case involves the Spouses Anton and Eileen Lim as petitioners against Uni-Tan Marketing Corporation as the respondent. The dispute originated from a complaint for unlawful detainer filed by Uni-Tan Marketing Corporation against the Lim spouses in the Metropolitan Trial Court of Manila, specifically Branch XI, under Civil Case No. 163168-CV. The complaint was filed on an unspecified date, and after the parties submitted their respective position papers, the Metropolitan Trial Court rendered a decision on August 6, 1999. The court ruled in favor of the plaintiff, ordering the Lim spouses to vacate the premises located at 1578-C Mayhaligue St., Sta. Cruz, Manila, and to pay monthly rentals of P12,500.00 starting from May 1998, along with attorney's fees amounting to P10,000.00.

On August 27, 1999, within the reglementary period, the Lim spouses filed a Notice of Appeal to the Regional Trial Court of Manila, which was docketed as Civil Case No. 99-951-39. On February 7,...

Facts:

1. Unlawful Detainer Case:

   • Respondent Uni-Tan Marketing Corporation filed an unlawful detainer case against petitioners Spouses Anton and Eileen Lim before the Metropolitan Trial Court (MTC) of Manila, Branch XI, docketed as Civil Case No. 163168-CV.
   • The MTC ruled in favor of Uni-Tan, ordering the Lim spouses to vacate the premises, pay monthly rentals, attorney’s fees, and costs of the suit.

2. Appeal to Regional Trial Court (RTC):

   • The Lim spouses appealed the MTC decision to the RTC, which reversed the MTC ruling and dismissed the complaint, declaring the Lim spouses not liable for rentals, attorney’s fees, or costs.

3. Execution of Judgment:

   • During the pendency of the appeal, the MTC judgment was executed, and some of the Lim spouses' properties were sold at auction.
   • The RTC later ordered the return of unsold items but upheld the execution sale of 17 items due to the Lim spouses' failure to file a supersedeas bond to stay execution.

4. Petition to the Court of Appeals (CA):

   • The Lim spouses filed a Petition for Review with the CA, challenging the RTC’s decision and order.
   • The CA dismissed the petition outright for procedural flaws, specifically the failure to attach a duplicate original or certified true copy of the MTC decision.

5. Supreme Court Petition:

   • The Lim spouses elevated the case to the Supreme Court, arguing that they substantially complied with procedural requirements and that the RTC erred in not awarding damages.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Mandatory Procedural Requirements:

   • Section 2, Rule 42 of the Rules of Court requires that a petition for review must be accompanied by duplicate originals or certified true copies of the assailed decision. Failure to comply with this requirement results in the outright dismissal of the petition.
   • The Lim spouses’ claim of substantial compliance was rejected because the copy they submitted did not meet the criteria for a duplicate original under Administrative Circular No. 3-96.

2. Immediate Execution in Ejectment Cases:

   • Under Section 19, Rule 70 of the Rules of Court, immediate execution of a judgment in favor of the plaintiff in an ejectment case is mandatory unless the defendant files a supersedeas bond and makes periodic deposits of rent.
   • Since the Lim spouses failed to file a supersedeas bond, the execution of the judgment was lawful, and neither the plaintiff nor the sheriff could be held liable for damages.

3. Damnum Absque Injuria:

   • The principle of damnum absque injuria applies here. The loss suffered by the Lim spouses was a result of their own failure to follow procedural rules, not any wrongful act by the respondent. Therefore, no damages could be awarded.

Conclusion:

The Supreme Court denied the petition, affirming the CA’s dismissal of the case. The Lim spouses’ failure to comply with procedural requirements and their own inaction in filing a supersedeas bond justified the dismissal and the denial of their claims for damages.