Case Summary (G.R. No. L-44001)
Background of the Case
This case involves a dispute over public market stalls in Baliuag, Bulacan, following the destruction of the market by fire in February 1956. Members of the Bulaong Group, having constructed the stalls at their own expense and made subsequent rental payments to the municipality, entered into sub-lease agreements with the Mercado Group in 1972. The municipality later canceled the leases of the Bulaong Group, declaring the Mercado Group as the rightful lessees based on Municipal Ordinance No. 14, which prohibited subleasing.
Summary Judgment Proceedings
The Bulaong Group filed complaints to recover their stalls and seek damages. During pre-trial proceedings, both parties stipulated many facts, leading the Mercado Group to file for summary judgment, arguing that no genuine issues of fact remained. The Bulaong Group acknowledged a single issue of fact requiring evidence—actual damages. Despite submitting affidavits to support their claims, the Mercado Group did not object or request a hearing on the matter of damages. On October 24, 1975, the trial court issued a summary judgment, rejecting the municipality's claim for ownership of the stalls, declaring the Bulaong Group as builders in good faith, and awarding them the value of their stalls with stipulations.
Appeals and Court of Appeals Rulings
Following the summary judgment, the Mercado Group filed for reconsideration, which the court denied. They subsequently attempted to appeal on January 7, 1976, but the trial court ruled that their appeal was filed outside the reglementary period. The Mercado Group then sought relief from the Court of Appeals through a special civil action of certiorari and prohibition, challenging the summary judgment and claiming denial of due process due to lack of a formal hearing on damages.
Upon review, the Court of Appeals affirmed the trial court's decision and clarified that the summary judgment procedure was valid, stating that any error in judgment regarding evidentiary appreciation did not deprive the court of jurisdiction. They emphasized that the Mercado Group’s failure to perfect the appeal within the required timeframe precluded their ability to challenge the summary judgment through certiorari.
Supreme Court Findings
The Supreme Court upheld the Court of Appeals' ruling, reiterating that the petitioners had failed to perfect an appeal from the summary judgment within the allowed period, and that any resulting errors by the trial court in its judgment did not constitute a lack of jurisdiction. The court maintained that errors made in the exercise of jurisdiction are only correctable via appeal, not certiorari.
Determination of Builder
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Case Background
- The case involves petitioners Paz Mercado and others against the Hon. Court of Appeals and several respondents including Benigno Puno and Lolita C. Bulaong.
- The main legal question is whether a special civil action of certiorari can be pursued to reverse a judgment of the Regional Trial Court that became final due to failure to appeal within the prescribed period.
- The petitioners claim the trial court applied the wrong provision of the Civil Code and rendered summary judgment without due process regarding damages.
Parties Involved
- Petitioners: Bulaong Group, former individual lessees of market stalls in Baliuag, Bulacan.
- Respondents: The Mercado Group (sub-lessees of the stalls), the Municipality of Baliuag, and the judges involved in the case.
Historical Context
- The Bulaong Group had been leasing stalls since 1956, constructed new stalls after a fire in 1956, and paid rentals to the Municipality.
- In 1972, the Bulaong Group sub-leased their stalls to the Mercado Group.
- The Municipality canceled the leases with the Bulaong Group based on Municipal Ordinance No. 14, which prohibited sub-leasing.
Legal Proceedings
- The Bulaong Group filed multiple complaints for recovery of their stalls and damages against the Mercado Group.
- The Mercado Group moved for summary judgment, claiming no genuine issues of fact remained.
- The Bulaong Group opposed the motion, asserting a need for a hearing to establish damages but did not formally request a hearing