Case Digest (G.R. No. L-74766)
Facts:
Domingo Vergara, Sr. v. Hon. Jose T. Suelto, Presiding Judge, Municipal Trial Court in Davao City, Branch IV, Manolito Guinoo, Romeo Montebon and Porferio Cabase, G.R. No. 74766, December 21, 1987, the Supreme Court First Division, Narvasa, J., writing for the Court.
Petitioner Domingo Vergara, Sr. sued private respondents Manolito Guinoo, Romeo Montebon and Porferio Cabase in the Municipal Trial Court (docketed Civil Case No. 343‑D‑M) for illegal detainer. Vergara alleged he owned a commercial building divided into three sections, each occupied by the defendants as lessees on month‑to‑month tenancy; that they had defaulted in payment of rents (rent originally P350 later P450); that his counsel sent demand/termination letters effective end of December 1985 and demanded vacation; that defendants acknowledged verbally they would leave but requested a three‑month extension; and that despite these exchanges defendants later refused to vacate, asserting instead that the lot had been ordered reverted to the public domain in a separate RT C action (Civil Case No. 16192). The complaint asserted nonpayment and sought ejectment.
The defendants answered, denying material averments including plaintiff’s ownership and the existence/validity of leases, asserting they occupied as owners and claiming title by virtue of membership in a landless association and the RT C judgment in Civil Case No. 16192. Vergara replied, stressing neither party was bound by that separate RT C action, that the ejectment concerned possession of his commercial building and unpaid rents, and that defendants’ denials were unfounded.
On March 7, 1986 Vergara filed a verified Motion for Summary Judgment (with eight annexes: two written leases, demand letters, a receipt showing partial payment by Montebon, defendants’ own letters, and the RT C order indicating the parties were not bound). The motion argued that, except as to amount of damages, no genuine issue of material fact existed, that defendants’ claimed title was irrelevant and tenuous, and that defendants were estopped to deny the landlord’s title (citing Civil Code provision on tenant estoppel).
The defendants filed an Opposition to Motion for Summary Judgment and a Motion to Dismiss, contending they had specifically denied material allegations, raised affirmative defenses and genuine issues (including an alleged real controversy as to title and ownership which, they argued, ousted the MTC’s jurisdiction and made the action one for reivindicacion rather than accion interdictal). Vergara filed a reply.
The respondent judge issued two orders dated April 15, 1986. The first denied defendants’ motion to dismiss, holding the case was properly an unlawful detainer action and that under Section 33 of Batas Pambansa Big. 129 the court could resolve ownership to determine possession. The second order denied Vergara’s motion for summary judgment, finding that defendants’ answer specifically denied material allegations and raised affirmative defenses so that a genuine issue existed and a trial was required.
Petitioner filed a special civil action of mandamus directly with the Supreme Court to compel the MTC judge to grant his motion for summary judgme...(Pro-only)
Issues:
- May the appropriateness of summary judgment be so manifest that a trial judge has a duty to grant the plaintiff’s motion for summary judgment in an unlawful detainer case?
- Was it proper for the petitioner to file directly with the Supreme Court an application for a writ of mandamus against a municipal trial court when the Court of Appeals and the Regional Trial Court also have jurisdict...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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