Case Summary (G.R. No. 123462)
Relevant Facts
On December 7, 1993, Tradal Ventures and Management Corporation (Tradal) executed a contract with Lavibo for the sale of the aforementioned unit, with a purchase price of P1,500,000.00. The payment terms included multiple installments, with the stipulation that the buyer would not take possession of the property until the full loan release from BPI-Family Bank. Subsequently, on January 11, 1994, Tradal allowed Lavibo to occupy the townhouse unit after she provided two postdated checks totaling P330,000.00. However, these checks were dishonored due to a closed account.
Procedural Background
After Tradal demanded that Lavibo vacate the premises on September 19, 1994, and she failed to comply, Tradal filed an ejectment complaint against her and Bargas in the Metropolitan Trial Court (MeTC) of Parañaque. The defendants did not file a substantive answer but a motion seeking dismissal of the complaint based on lack of cause of action and claims of jurisdiction.
Metropolitan Trial Court Decision
On February 27, 1995, the MeTC dismissed Tradal's complaint, stating that while it was labeled as an ejectment case, its essence involved a rescission of the contract. The MeTC pointed out that ejectment remedies are only available after a formal rescission of such contracts, which had not occurred. The court noted that jurisdiction over rescission cases relies on the Regional Trial Court (RTC), indicating that Tradal’s action was indeed premature.
Regional Trial Court Ruling
The RTC upheld the MeTC's decision, affirming that the complaint was improperly filed and articulated that the contract remained valid and unrescinded, reinforcing the unique jurisdictional concerns in ejectment cases.
Court of Appeals Ruling
Tradal then filed a petition for review with the Court of Appeals, which on November 29, 1995, reversed the lower courts’ decisions. The appellate court ruled that Lavibo and Bargas were to vacate the property and pay rental values for their continued occupancy. It ordered that the initial payment be credited toward their rental obligations.
Supreme Court Decision
Upon further appeal, the Supreme Court reinstated the RTC's ruling, concluding that the true nature of Tradal's complaint was for rescission rather than ejectment. Consequently, it ruled that jurisdiction lay with the RTC, and since the contract to
...continue readingCase Syllabus (G.R. No. 123462)
Case Overview
- The case is an appeal from the decision of the Court of Appeals dated November 29, 1995, and its resolution denying a motion for reconsideration dated January 9, 1996.
- Petitioners are Ofelia C. Lavibo and Benjamin L. Bargas, while the respondents are Hon. Court of Appeals and Tradal Ventures and Management Corporation.
- The Supreme Court reviewed the nature of the complaint originally filed before the Metropolitan Trial Court (MeTC).
Background of the Case
- On December 7, 1993, Tradal Ventures and Management Corporation entered into a contract to sell a unit in Shenandoah Twinhomes, Parañaque, Metro Manila, to Ofelia Lavibo for P1,500,000.00, with specific payment terms.
- The contract stipulated that Lavibo could not occupy the property until the full payment was made.
- Despite this agreement, Tradal permitted Lavibo to occupy the unit after she issued two postdated checks totaling P330,000.00.
- These checks were dishonored due to the account being closed.
Events Leading to Ejectment
- Tradal demanded that Lavibo vacate the premises on September 19, 1994, after h