Case Summary (G.R. No. 84330)
Facts of the Case
The private respondents, as plaintiffs, filed a complaint in the Metropolitan Trial Court of Manila (Branch 29) against petitioner Ascue, alleging non-payment of rent for the months of May, June, and July 1986, totaling P5,625.00. The petitioner contended that the Metropolitan Trial Court lacked jurisdiction over the case, claiming it should be heard by a Regional Trial Court due to the subject matter being incapable of pecuniary estimation. The Metropolitan Trial Court denied the motion to dismiss based on its jurisdiction and ruled that the case was properly filed.
Procedural History
The petitioner appealed the decision of the Metropolitan Trial Court to the Regional Trial Court of Manila, which dismissed the appeal on March 20, 1987, citing it was premature and stating that the appropriate remedy was a special civil action for certiorari. Petitioner subsequently filed a direct appeal with the Supreme Court, which was referred to the Court of Appeals for concurrent jurisdiction.
Court of Appeals Decision
On July 25, 1988, the Court of Appeals upheld the Regional Trial Court's decision. It clarified that the jurisdiction of courts in consignation cases is contingent upon the amount consigned, reiterating that consignation is a form of payment which requires prior demand. The appellate court concluded that since the amount due was determinable and fell within the jurisdiction of the Metropolitan Trial Court, it could not be said that the appeal was procedurally incorrect.
Legal Principles Involved
The case hinges on the principles of consignation, which involves depositing a debt when the creditor refuses to accept payment. It was determined that for consignation to be valid, the requisite elements include the existence of a debt and the placing of that debt's amount in the court's hands. In this case, the sum of P5,625.00 was capable of pecuniary estimation, affirming the jurisdiction of the Metropolitan Trial Court as per the provisions outlined in Batas Pambansa Blg. 129.
Petitioner’s Arguments
In his petition, Ascue argued that Consignation is under the jurisdiction of the Regional Trial Court due to its pecuniary nature and asserted that the Court of Appeals refused to address key procedural issues regarding proper recourse when a motion to dismiss is denied. He also claimed that the appellate court's decision was issued without considering pending incidents before the Supreme Court, potentially causing unnecessary burdens on the parties involved.
Resolution of the Supreme Court
The Supreme Court found no merit in the petitioner's arguments and upheld the decision of the Court of
...continue readingCase Syllabus (G.R. No. 84330)
Case Overview
- Petitioner: Ramon Y. Ascue
- Respondents: Hon. Court of Appeals (8th Division), Ramon Antonio, Salvador Salenga, and Ulipia Fernandez
- G.R. No.: 84330
- Date of Decision: May 08, 1991
- Lower Court: Regional Trial Court of Manila, Branch 52
Procedural History
- The case originates from a complaint filed on July 25, 1986, by private respondents against petitioner in the Metropolitan Trial Court of Manila.
- The complaint involved issues of rental payments and the refusal of the petitioner to accept the consigned rental amounts.
- A motion to dismiss was filed by the petitioner, claiming jurisdiction issues.
- The Metropolitan Trial Court denied the motion, asserting its jurisdiction over the case.
- Petitioner appealed the decision to the Regional Trial Court, which dismissed the appeal as premature and indicated that a special civil action for certiorari was the proper remedy.
- Petitioner subsequently filed a direct appeal to the Supreme Court, which referred the case to the Court of Appeals.
Factual Background
- Private respondents are lessees under petitioner, occupying specific units in a leased premises in Sampaloc, Manila.
- Monthly rentals for the occupied units were specified: P635.00 for one unit and P950.00 for the others.
- Petitioner allegedly refused to collect rentals for May, June, and July 1986, except for a partial payment from one respondent.
- Total rental due was P5,625.00, which the respondents sought to consign to the court due to the petitioner’s refusal to acc