Case Digest (G.R. No. 241699)
Facts:
Dennis T. Uy Tuazon, World Wiser International, Inc., and Jerzon Manpower and Trading, Inc. v. Myra V. Fuentes, G.R. No. 241699, August 04, 2021, Supreme Court Second Division, Inting, J., writing for the Court.The dispute concerns leases executed by husband Dennis T. Uy Tuazon over property that he and Myra V. Fuentes co-owned. The parcels (TCT Nos. 146276 and 146277) in Pasay City bore a building occupied by two companies owned by Tuazon and his family, World Wiser International, Inc. and Jerzon Manpower and Trading, Inc. While nullity of marriage proceedings between the spouses were pending (Branch 260, RTC, Parañaque City, Civil Case No. 07-0142), the RTC on August 24, 2012 authorized Fuentes to sell common properties to secure support pendente lite; the property was sold to Philippine Coast Guard Savings and Loan Association, Inc. (PCGSLAI). The nullity judgment became final on October 31, 2012, and liquidation of the subject property followed; the RTC approved a contract to sell to PCGSLAI on September 8, 2014.
On August 8, 2014 Fuentes served a notice to vacate World Wiser; Jerzon had already been ordered closed. World Wiser resisted and an unlawful detainer action ensued; World Wiser and Jerzon defended by producing lease contracts allegedly executed by Tuazon for the period July 1, 2012 to July 1, 2022. In response, Fuentes filed a separate complaint in RTC Branch 260 (Civil Case No. 14-0261) seeking declaration of nullity/annulment of those lease contracts on the ground that Tuazon acted without Fuentes’ written consent.
The RTC denied petitioners’ motion to refer the case to judicial dispute resolution and, after trial, rendered judgment on December 14, 2015 declaring both lease contracts null and void. Petitioners appealed to the Court of Appeals in CA-G.R. CV No. 107826, which in a Decision dated April 6, 2018 and Resolution dated August 1, 2018 affirmed the RTC, holding the leases void for lack of Fuentes’ writ...(Pro-only)
Issues:
- Did the RTC’s denial of referral to judicial dispute resolution (JDR) and the absence of a JDR session violate petitioners’ right to due process?
- Are the contracts of lease executed by Dennis T. Uy Tuazon over the spouses’ common property without Myra V. Fuentes’ written consent void?
- Should PCGSLAI’s late Motion to Intervene be allowed despite being filed ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)