Case Summary (G.R. No. 189145)
Factual Background
On April 26, 2005, the Sps. Jovellanos entered into a Contract to Sell with Palmera Homes, Inc., for a residential house and lot, with a total purchase price of P1,015,000.00. After a down payment of P91,500.00, they took possession of the property and agreed to pay monthly installments of P13,107.00 over ten years. Subsequently, Palmera Homes assigned its rights under the contract to Optimum Development Bank on August 22, 2006. Despite failing to make installment payments, Sps. Jovellanos did not vacate the property following Optimum's demand, prompting Optimum to file a complaint for unlawful detainer on November 3, 2006.
MeTC Ruling
On June 8, 2007, the MeTC ruled in favor of Optimum, ordering Sps. Jovellanos to vacate the property and pay P5,000.00 in damages for use and occupation. The MeTC found their possession was based on the now-canceled contract due to non-payment, and thus their right to possession had expired, constituting unlawful detainer.
RTC Findings
The RTC affirmed the MeTC's decision on December 27, 2007, rejecting Sps. Jovellanos's claims regarding a supposed compromise agreement and asserting that the MeTC did not err in refusing their belatedly filed answer. It held that the unlawful detainer action focused solely on possession, not on the merits of the contract.
CA Ruling
In an amended decision dated May 29, 2009, the CA reversed the RTC ruling, emphasizing that the case involved issues of jurisdiction concerning the validity of the Contract to Sell and thus could not be resolved through unlawful detainer. The CA concluded that the matter was one incapable of pecuniary estimation, falling under the jurisdiction of the RTC.
Supreme Court's Analysis
The Supreme Court granted Optimum's petition, emphasizing that the nature of an unlawful detainer action is determined by the allegations in the complaint, particularly for cases where possession is initially lawful but later becomes illegal. The Court underscored that the MeTC had the authority to resolve questions of ownership when necessary to adjudicate possession rights, including matters related to contract interpretation.
Applicability of RA 6552
The ruling recognized that the cancellation of the Contract to Sell was valid under Republic Act No.
...continue readingCase Syllabus (G.R. No. 189145)
Background of the Case
- The case involves a petition for review on certiorari filed by Optimum Development Bank against Spouses Benigno V. Jovellanos and Lourdes R. Jovellanos.
- The petition challenges the Decision dated May 29, 2009, and Resolution dated August 10, 2009, of the Court of Appeals (CA), which reversed the ruling of the Regional Trial Court (RTC) affirming the Metropolitan Trial Court's (MeTC) decision in favor of Optimum.
- The underlying dispute centers on a Contract to Sell for a residential property located in Caloocan City.
Facts of the Case
- On April 26, 2005, the Jovellanos spouses entered into a Contract to Sell with Palmera Homes, Inc. for a total price of P1,015,000.00, paying a down payment of P91,500.00 and agreeing to monthly installments.
- On August 22, 2006, Palmera Homes assigned its rights under the contract to Optimum.
- Optimum issued a Notice of Delinquency on April 10, 2006, due to the Jovellanos' failure to pay their monthly dues, followed by a demand to vacate the property on May 25, 2006.
- Subsequently, Optimum filed a complaint for unlawful detainer against the Jovellanos spouses in the MeTC on November 3, 2006, after their refusal to vacate the premises.
MeTC Ruling
- The MeTC ruled in favor of Optimum on June 8, 2007, ordering the Jovellanos spouses to vacate the property and pay reasonable compensation for its use.
- The court found that their possession was based on the Contract to Sell, which had bee