Case Summary (G.R. No. 156142)
Background of the Case
On June 2, 1997, a Contract to Sell was executed between PDC and the spouses Guerrero, wherein PDC agreed to sell a property, secured by Transfer Certificate of Title No. T-51529, for a total consideration of ₱2,374,000. The agreement stipulated a down payment of ₱594,000 with the remaining balance to be paid over 120 months commencing from May 30, 1997. However, by February 5, 2002, PDC initiated a complaint for unlawful detainer against the spouses Guerrero, citing their failure to make payments past June 1, 2000, resulting in the cancellation of the contract on November 19, 2001.
Legal Proceedings Initiated
The unlawful detainer proceeding was filed as Civil Case No. 6293 in the Metropolitan Trial Court (MeTC) of Las Piñas City. In response, the spouses Guerrero filed an Answer with Reservation, asserting that the complaint improperly combined issues beyond the jurisdiction of the MeTC with the unlawful detainer action. Subsequently, on April 10, 2002, they filed a Petition for Prohibition in the RTC of Las Piñas City, seeking to quash the complaint in Civil Case No. 6293 on the grounds that the inclusion of a contract cancellation claim, which could not be adjudicated by the MeTC, invalidated the proceedings.
RTC's Ruling and Further Developments
While the RTC Branch 201 was considering the Petition for Prohibition, the MeTC proceeded with Civil Case No. 6293 and ruled in favor of PDC on September 30, 2002. The spouses Guerrero appealed this decision to RTC Branch 197, but their appeal was subsequently dismissed on procedural grounds on June 20, 2003, due to their failure to file required documents.
Application of Prohibition Doctrine
In denying the Petition for Prohibition, the RTC emphasized that the remedy of prohibition is not applicable to actions that have already occurred, confirming that the act being challenged—the filing of the unlawful detainer case—had indeed transpired. The court referenced pertinent jurisprudence, illustrating that prohibition is designed to restrain prospective actions rather than remedy completed actions. It ruled that, since the contract cancellation occurred prior to the filing of the unlawful detainer case, the jurisdiction of the MeTC remained valid.
Adequate Legal Remedy Considerations
Furthermore, the RTC noted that the spouses Guerrero had alternative remedies available, such as a Motion to Dismiss the unlawful detainer action on jurisdictional grounds, or raising these defenses directly in their answer. The court stated that Section 13, Rule 70 of the 1997 Rules of Civil Procedure permits motions to dismiss based on a lack of jurisdiction in such cas
...continue readingCase Syllabus (G.R. No. 156142)
Case Overview
- This case is a Petition for Review on Certiorari involving petitioners Spouses Alvin and Mercury Guerrero against Hon. Lorna Navarro Domingo, presiding judge of the Regional Trial Court (RTC), Branch 201 of Las Piñas City, and Pilar Development Corporation (PDC).
- The petition challenges the RTC's Order dated November 18, 2002, which denied the spouses Guerrero's Petition for Prohibition against the unlawful detainer proceedings initiated by PDC.
Factual Background
- On June 2, 1997, the spouses Guerrero entered into a Contract to Sell with PDC concerning a property identified by Transfer Certificate of Title (TCT) No. T-51529, with a total consideration of ₱2,374,000.00.
- The contract stipulated a down payment of ₱594,000.00 and a remaining balance payable over 120 months starting May 30, 1997.
- PDC filed a Complaint for Unlawful Detainer against the spouses Guerrero on February 5, 2002, citing their failure to make payments beyond June 1, 2000, and subsequently canceled the Contract to Sell on November 19, 2001.
Procedural History
- The complaint was filed in the Metropolitan Trial Court (MeTC) of Las Piñas City and was docketed as Civil Case No. 6293.
- The spouses Guerrero filed an Answer With Reservation, arguing against the mixing of causes of action in the unlawful detainer complaint.
- On April 10, 2002, the spouses Guerrero filed a Petition for Prohibition with the RTC, seeking to quash the unlawful detai