Case Summary (G.R. No. 198172)
Antecedent Facts
Regulus Development, Inc. owned the San Juan Apartments and leased units 2002-A and 2002-B to Antonio Dela Cruz. Each lease was for a duration of one month, subject to automatic renewals unless terminated by written notice. Upon sending a termination letter, the petitioner filed for ejectment in the Metropolitan Trial Court (MTC) after the respondent refused to vacate. The MTC ruled in favor of the petitioner. Subsequent appeals led to a ruling by the RTC affirming the MTC's decision, but the Court of Appeals (CA) later reversed the lower court’s decisions, ultimately dismissing the ejectment case.
Court Decisions and Dismissals
Following the dismissal of the ejectment case, the RTC granted the petitioner’s motion to withdraw the consigned rental payments deposited by the respondent, asserting it had the authority to do so under its equity jurisdiction. The respondent's petitions against these orders were dismissed by the CA, and subsequent appeals to the Supreme Court supported these findings, solidifying the RTC's jurisdiction over the orders.
The Petition
In its petition for review on certiorari, the petitioner contested the CA’s reversal of the RTC's orders regarding the levy of the respondent's property. The petitioner maintained that (1) the RTC’s actions fell within its equity jurisdiction, (2) the respondent's subsequent redemption of the property rendered the CA’s petition moot, and (3) procedural deficiencies regarding the verification of the petition should not have led to its dismissal.
Procedural Issues and Jurisdiction
The Supreme Court addressed procedural arguments, asserting that procedural defects such as the absence of a notarial seal on the Verification and Certification against Forum Shopping do not necessarily invalidate a petition factually compliant with the rules. The Court reinforced the principle that courts strive to resolve cases based on substantive merits rather than technicalities. Moreover, it stated that the CA rightly refused to dismiss the petition because the jurisdictional issue raised was inherently justiciable.
Jurisdictional Scope of the RTC
The Supreme Court delineated the distinction between equity jurisdiction and appellate jurisdiction. The RTC's orders allowing the withdrawal of funds were issued under its equity jurisdiction, not its appellate jurisdiction, as the ejectment case’s dismissal p
...continue readingCase Syllabus (G.R. No. 198172)
Case Citation
- 779 Phil. 75
- G.R. No. 198172
- Decided on January 25, 2016
- Second Division
Overview
- The case involves a petition for review on certiorari filed by Regulus Development, Inc. (petitioner) against Antonio Dela Cruz (respondent).
- The petition challenges the decision of the Court of Appeals (CA) dated November 23, 2010, and the resolution dated August 10, 2011, in CA-G.R. SP No. 105290.
Antecedent Facts
- Regulus Development, Inc. owns San Juan Apartments in Pasay City, where Antonio Dela Cruz leased two units in 1993 and 1994.
- Each lease contract stipulated a one-month lease with automatic renewals unless terminated by written notice from the petitioner.
- The petitioner sent a termination letter, but the respondent refused to vacate, prompting the petitioner to file an ejectment complaint on May 1, 2001.
- The Metropolitan Trial Court (MTC) ruled in favor of the petitioner, ordering the respondent to vacate and pay due rentals.
- The respondent appealed to the Regional Trial Court (RTC), which affirmed the MTC's decision.
- The CA reversed the lower courts’ decisions in CA-G.R. SP No. 69504, dismissing the ejectment case as final and executory on March 19, 2003.
Orders for Payment of Rentals
- The petitioner filed a motion to withdraw funds from the rentals consigned by the respondent to the RTC.
- On July 25, 2003, the RTC granted the motion, allowing the petitioner to withdraw the consigned rentals based on equity and justice.
- The RTC denied the respondent’s motion for reconsideration on November 28, 2003.
- Subsequently, the RTC issued a writ