Case Summary (G.R. No. 247410)
Lease and Unlawful Detainer Proceedings
The five-year lease over the Makati property expired April 15, 1997. Toyota’s continued possession after that date became unlawful. Insular Life demanded vacation, then sued for ejectment. The MeTC found Toyota in unlawful possession, awarded double rent at P585,640 monthly from the lease termination date until turnover of possession, plus P50,000 attorney’s fees and P20,000 litigation expenses.
Writ of Execution and Clarificatory Orders
Upon withdrawal of appeals, MeTC issued a writ of execution on August 12, 1998, which incorporated the rent award “from April 15, 1997.” The sheriff levied on Toyota’s properties and bank accounts with auction set. Toyota sought certiorari relief before the RTC, charging MeTC with grave abuse for retroactively computing rent. Meanwhile, MeTC issued two clarificatory orders (September 14 and October 28, 1998) inserting “as of April 15, 1997” and reinstating “a month” into the dispositive portion to align with its ratio decidendi.
RTC Certiorari and Injunction
The RTC enjoined the auction and, on September 30, 1998, voided the writ of execution for MeTC’s alleged grave abuse in amending its decision’s dispositive portion. The court held the clarifications insufficient to cure ambiguity and ordered Toyota to consign accrued rentals. Insular Life’s reconsideration was denied March 5, 1999.
Compromise Agreement
While the certiorari petition was pending before this Court, Toyota and Insular Life entered a conditional compromise dated May 7, 1999. It required: (a) transfer of three Toyota vehicles worth P1.5 M; (b) issuance of twelve post-dated corporate checks totaling P6.5 M; and (c) posting a surety bond of P6.5 M from Insular Life’s approved surety list.
Supreme Court’s Remand and Findings on Compromise
By Resolution dated August 8, 2001, the Supreme Court remanded to the RTC to determine whether Toyota fulfilled the compromise conditions. RTC found Toyota failed to deliver valid checks (account under garnishment) and a compliant surety bond, and that substitute real-property collateral was unacceptable. Each party submitted supplemental memoranda; Insular Life urged strict compliance; Toyota claimed substantial compliance hindered by RTC’s voiding of the writ.
Conditional Nature of the Agreement
Applying Civil Code doctrine on suspensive conditions, the Court held that the issuance of post-dated checks and bond were positive suspensive conditions. Their non-fulfillment meant the compromise never acquired obligatory force. Toyota’s inability to meet these conditions prevented any binding agreement; Insular Life had no obligation to lift garnishment or accept collateral.
Certiorari Jurisdiction and Prematurity
On the merits of the petition, the Court found Toyota’s certiorari before the RTC premature. Under Rule 65, certiorari lies only where no plain, speedy, and adequate remedy exists; Toyota could have employed in-court remedies such as a motion to quash the writ or motion to clarify the dispositive portion in MeTC. The RTC should have allowed the MeTC to correct any error.
Interpretation of the Dispositive Portion
Although generally only the dispositive portion controls execution, recognized exceptions permit reference to the body of the decision where ambiguity exists or extensive discussion supports a broader interpretation. Here, MeTC’s findings and conclusions clearly established rent computation “from April 15, 1997.” The insertion of that date in the writ and subsequent clarificatory orders merely gave effect to what the body of the decision had expressed. The RTC erred in nullifying the entire writ over an inadvertent omission in the dispo
...continue readingCase Syllabus (G.R. No. 247410)
Facts of the Case
- Toyota Bel-Air, Inc. leased a 3,700-sqm lot and building from Insular Life Assurance Company, Ltd. from April 16, 1992 to April 15, 1997.
- Upon lease expiry, Toyota remained in possession despite repeated demands to vacate.
- On January 28, 1998, Insular Life filed a complaint for unlawful detainer in MeTC, Makati City.
- On July 3, 1998, MeTC rendered judgment ordering Toyota to vacate, to pay P585,640.00 per month as reasonable compensation until surrender of possession, P50,000.00 attorney’s fees, P20,000.00 litigation expenses, and costs of suit.
Pleadings, Motions, and Appeals
- July 23, 1998: Insular Life moved for execution of MeTC decision.
- Toyota filed a notice of appeal; Insular Life filed a notice of partial appeal on compensation.
- Both parties later withdrew their appeals; on August 12, 1998, MeTC approved withdrawal and issued Writ of Execution.
- Deputy Sheriff levied on Toyota’s assets and scheduled auction for August 28, 1998.
- August 24, 1998: Toyota filed a certiorari petition with the RTC, secured a TRO to enjoin the sale.
- August 28, 1998: Insular Life moved MeTC to clarify its July 3 decision.
- September 14, 1998: MeTC issued first clarificatory order adding “as of April 15, 1997” to compensation.
- October 28, 1998: MeTC issued second clarificatory order restoring phrase “at the rate of P585,640.00 a month as of April 15, 1997.”
RTC Proceedings and Decision
- September 25, 1998: Toyota moved to consign P1,171,280.00 for July and August 1998 rentals.
- September 30, 1998: RTC Branch 148 nullified the Writ of Execution for grave a