Case Summary (G.R. No. 142950)
Applicable Law
This case is governed by the 1987 Philippine Constitution, as the decision was rendered in 2001.
Factual Background
The case revolves around an ejectment suit initiated by Equitable PCI Bank against Ku Giok Heng, the father of Rosita Ku, who was not made a party to the initial ejectment proceedings. Rosita Ku argued that her exclusion from the case constituted a violation of her right to due process. The property in question was mortgaged to the bank by Noddy Dairy Products, Inc., which failed to repay its loan, leading to the property’s foreclosure. After the foreclosure, the bank was issued a Certificate of Sale and subsequently acquired the title to the property.
Lower Court Proceedings
In May 1989, a Metropolitan Trial Court (MeTC) action for ejectment against Ku Giok Heng was filed due to non-payment of rent. The MeTC ruled in favor of the bank, ordering Ku Giok Heng to vacate the premises. Ku Giok Heng did not appeal this decision. Instead, both he and Rosita Ku lodged a case in the Regional Trial Court (RTC) to nullify the MeTC ruling, which the RTC dismissed for lack of merit. The RTC's dismissal was appealed to the Court of Appeals (CA), where Rosita Ku argued that she had been denied due process as she was not a party in the initial suit.
Court of Appeals Ruling
The Court of Appeals sided with Rosita Ku, emphasizing that her absence as a party to the ejectment case precluded the enforcement of the MeTC’s ruling against her. This decision prompted Equitable PCI Bank to elevate the case for consideration by the Supreme Court.
Supreme Court's Analysis
The Supreme Court centered on whether a person can be evicted pursuant to a judgment rendered against another party when they were not joined in the initial action. Generally, a judgment binds only the parties involved in that proceeding. However, judgments in ejectment cases have broader implications if the ejectment involves parties or persons deemed to be in a position analogous to that of the defendant. The Court recognized that as a daughter of the defendant, Rosita Ku could be affected by the outcome of the ejectment case because of familial ties and her potential occupancy of the property in question.
Discussion on Procedural Objections
Equitable PCI Bank objected to the timing of the appeal, claiming that the CA decision was received later than the date indicated, which impacted the timeliness of their petition. Further, the bank's representative submitted an affidavit claiming an honest error regarding the date of receipt. The Court assessed whether the service of documents upon an agent, who wa
...continue readingCase Syllabus (G.R. No. 142950)
Case Overview
- The central issue in this case revolves around whether a person can be evicted based on a decision made in an ejectment case in which she was not a party.
- The Court of Appeals ruled in favor of the respondent, asserting that due process would be violated if a party not joined in the ejectment case were evicted.
Factual Background
- On February 4, 1982, Rosita Ku, acting in her capacity as treasurer of Noddy Dairy Products, Inc., along with Ku Giok Heng, mortgaged a residential property in La Vista, Quezon City, to Equitable Banking Corporation (now Equitable PCI Bank) to secure a loan for the corporation.
- The property was registered under Rosita Ku's name, but Noddy, Inc. defaulted on the loan, leading to the extrajudicial foreclosure of the property by the bank.
- After failing to redeem the property, the bank was issued a certificate of sale, and the Transfer Certificate of Title was subsequently canceled and a new one issued in the bank's name on December 10, 1984.
Procedural History
- On May 10, 1989, Equitable PCI Bank initiated an ejectment action before the Quezon City Metropolitan Trial Court (MeTC) against Ku Giok Heng, alleging non-payment of rent after allowing him to occupy the property.
- The MeTC ruled in favor of the bank on December 8, 1994, ordering Ku Giok Heng to vacate the premises due to the absence of a valid lease agreement and his failure to pay rent.
- Ku Giok Heng did not appeal the MeTC's decision. Instead, he and Rosita Ku