Case Summary (G.R. No. 128743)
Facts of the Case
Angel Chaves, Inc., the owner of a commercial building in Cagayan de Oro City, leased the premises to various business establishments, including Oro Cam Enterprises, Inc. Following the expiration of lease contracts on June 30, 1989, the private respondent sought new lease agreements with increased rentals, demanding compliance from the lessees, including Oro Cam Enterprises. When the lessees failed to comply, Angel Chaves filed a complaint for unlawful detainer in the Municipal Trial Court in Cities, initiating Civil Case No. 13040.
Legal Proceedings Overview
The Municipal Trial Court rendered a decision on July 23, 1992, dismissing complaints against some defendants, including Oro Cam Enterprises, but ordered the ejectment of another defendant, Alfredo Co. However, the RTC later reversed the MTCC's ruling, ordering all defendants, including Oro Cam, to vacate the premises and pay damages. Vicente Manzano, the brother of one of the defendants, attempted to appeal this decision but was ultimately dismissed for being out of time.
Execution Motion and Petition for Certiorari
Following appellate affirmation, Angel Chaves filed a motion for a writ of execution against Constancio Manzano and Oro Cam Enterprises. The petitioner opposed this, arguing that it had not been impleaded as a party in the unlawful detainer case. Oro Cam subsequently filed a petition for certiorari against the RTC, seeking a preliminary injunction to halt the execution.
Issuance of Preliminary Injunction
The RTC initially granted Oro Cam Enterprises a preliminary injunction, preventing the enforcement of the writ of execution. However, Angel Chaves filed a petition for certiorari with the Court of Appeals, which later annulled the RTC’s injunction order stating that the preliminary injunction was void.
Petitioner's Contentions
In its petition, Oro Cam Enterprises raised two primary issues: first, whether it was privy to the lease agreement between Angel Chaves and Constancio Manzano; and second, whether the Court of Appeals acted with gravely excessive discretion in declaring the trial court's injunction null. Petitioner argued its distinct corporate status and its exclusion from the original unlawful detainer case.
Court of Appeals' Reasoning and Decision
The Court of Appeals affirmed the lower court's dismissal of the injunction, finding that Oro Cam was indeed privy to the lease agreement as evidenced by judicial admissions made in court, such as rental payments made by Oro Cam to Constancio Manzano. Consequently, Oro Cam was found to be a party to the leasing arrangements and therefore subject to the outcomes of the unlawful detainer case.
Impact of the Decision
The appellate court concluded that it was inappropriate for Oro Cam to challenge jurisdiction at such a late stage, especial
...continue readingCase Syllabus (G.R. No. 128743)
Case Overview
- This case is a petition for review regarding a decision made by the Court of Appeals on November 27, 1996.
- The decision annulled an injunctive order from the Regional Trial Court (RTC) which had enjoined the enforcement of a writ of execution in an ejectment case.
- The RTC was also ordered to dismiss the petition for certiorari filed by Oro Cam Enterprises, Inc. due to lack of cause of action.
Factual Background
- Angel Chaves, Inc. is the owner of a commercial building in Cagayan de Oro City leased to various business establishments.
- On January 15, 1991, Angel Chaves, Inc. filed a complaint for unlawful detainer against the lessees in the Municipal Trial Court in Cities (MTCC), Cagayan de Oro City, under Civil Case No. 13040.
- The complaint asserted that the leases were for a uniform period of one year since 1986, with the latest contracts executed on July 31, 1988, outlining the monthly rentals.
Lease Agreements and Demand for Increased Rent
- The leases stated specific amounts for rentals, with the latest agreed amounts highlighting an increase from July 1, 1989, to June 30, 1990.
- A demand for payment of increased rent was made by Angel Chaves, Inc. after sending forms for new lease contracts to the lessees.
- The failure of the lessees to comply led to the filing of the unlawful detainer suit.
MTCC Decision
- The MTCC rendered a decision on July 23, 1992, dismissing the complaint against three of the defendants, including