Case Digest (G.R. No. 137884) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Insular Life Assurance Company, Ltd. v. Toyota Bel-Air, Inc., the petitioner, Insular Life, and the respondent, Toyota Bel-Air, Inc., entered into a five-year Contract of Lease covering a 3,700-sqm building in Pasong Tamo Street, Makati City, from April 16, 1992 to April 15, 1997. Upon expiration, Toyota unlawfully retained possession. On January 28, 1998, Insular Life filed an Unlawful Detainer complaint in the Metropolitan Trial Court (MeTC), Branch 63. On July 3, 1998, the MeTC ordered Toyota to vacate, return possession, and pay reasonable compensation of ₱585,640.00 a month from April 15, 1997 until turnover, plus attorney’s fees (₱50,000.00), litigation expenses (₱20,000.00), and costs. Insular Life moved for execution on July 23; Toyota filed and then withdrew its appeal. On August 12, 1998, the MeTC issued a Writ of Execution commanding, among other things, payment of compensation “from April 15, 1997.” The Sheriff levied Toyota’s assets, garnished its bank accounts, Case Digest (G.R. No. 137884) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract of Lease and Unlawful Detainer
- Insular Life Assurance Company, Ltd. (Insular Life) leased a 3,700 sqm lot and building in Makati City to Toyota Bel-Air, Inc. (Toyota) from April 16, 1992 to April 15, 1997.
- Upon expiration, Toyota remained in possession and refused to vacate despite demands. Insular Life filed an unlawful detainer complaint in MeTC, Branch 63, Makati City on January 28, 1998.
- MeTC Decision, Execution, and Appeal Withdrawal
- On July 3, 1998, the MeTC rendered judgment ordering Toyota to (a) vacate and return possession, (b) pay reasonable compensation of ₱585,640.00 per month, (c) pay ₱50,000.00 attorney’s fees, ₱20,000.00 litigation expenses, and costs.
- Insular Life moved for execution; Toyota and Insular Life each filed appeals but later withdrew them. On August 12, 1998, MeTC approved withdrawal of appeals and issued a Writ of Execution specifying compensation “from April 15, 1997.”
- RTC Certiorari, Clarificatory Orders, and Consignation
- Toyota filed a petition for certiorari in RTC, Branch 148, Makati City on August 24, 1998, arguing the Writ unlawfully amended the dispositive portion by adding retroactive compensation. A TRO enjoined the auction of Toyota’s levied assets.
- MeTC issued two clarificatory orders: (a) September 14, 1998, inserting “as of April 15, 1997” (but omitting “a month”); (b) October 28, 1998, correcting to “at the rate of ₱585,640.00 a month as of April 15, 1997.”
- Toyota moved to consign ₱1,171,280.00 for July–August rentals. On September 30, 1998, the RTC nullified the Writ of Execution, declared the levy void, and allowed consignation. RTC denied reconsideration on March 5, 1999.
- Compromise Agreement and Remand
- A May 7, 1999 compromise provided Toyota would pay Insular Life ₱8 million via (a) delivery of vehicles worth ₱1.5 million, (b) twelve postdated checks for ₱6.5 million, (c) a surety bond.
- On remand, RTC found Toyota failed to comply with the checks and bond conditions. Insular Life refused substitute collateral. Both parties filed supplemental memoranda.
Issues:
- Whether the MeTC writ of execution was void for amending the dispositive portion of the decision by retroactive compensation from April 15, 1997.
- Whether the RTC erred in voiding the entire writ of execution instead of clarifying the compensation award.
- Whether RTC had jurisdiction to order consignation of rentals in a certiorari proceeding.
- Whether Toyota prematurely sought certiorari without exhausting available remedies in MeTC.
- Whether the May 7, 1999 compromise agreement became binding despite non-fulfillment of its suspensive conditions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)