Title
Vergara Sr. vs. Suelto
Case
G.R. No. L-74766
Decision Date
Dec 21, 1987
Petitioner Vergara sought ejectment of respondents for unpaid rentals; respondents claimed land reversion, but defenses were deemed sham. Supreme Court ruled summary judgment proper, annulling MTC's denial.
illegal detainer
summary judgment
genuine denial

Case Summary (G.R. No. L-74766)

Factual Background

The plaintiff alleged ownership of a commercial building comprising three sections, each occupied by the defendants as lessees on a month‑to‑month basis with rent originally PHP 350 later increased to PHP 450, and that the defendants defaulted in rental payments for many months. The plaintiff alleged that his lawyer sent each defendant a demand letter terminating the leases effective December 1985 for nonpayment and the plaintiff’s need of the property, demanding vacation by the end of December; the defendants replied by a joint letter acknowledging a verbal commitment to vacate but requesting a three‑month extension and one defendant made partial payment of arrears. The defendants later asserted that title to the land had been annulled in a separate case, that they occupied in the concept of owners as members of an association, and denied plaintiff’s ownership and the leases’ validity.

Pleadings and Motion for Summary Judgment

The plaintiff filed a verified motion for summary judgment supported by eight documents, asserting the defendants’ status as lessees shown by two written lease contracts, demand letters, an official receipt evidencing payment by one defendant, and the defendants’ own letters acknowledging the plaintiff’s demand and their commitment to vacate. The motion also relied on the absence of any binding effect of the separate reversion case, citing an order in that action indicating non‑binding status against the parties, and argued that the defendants were estopped from denying the plaintiff’s title.

Defendants’ Opposition and Trial Court Orders

The defendants filed an opposition and motion to dismiss contending that genuine issues of title and ownership precluded resolution by summary judgment, that their answer did not consist of a mere general denial because it specifically contradicted material averments, and that the Municipal Trial Court lacked jurisdiction because the real controversy was one of title requiring accion reivindicatoria rather than accion interdictal. The Municipal Trial Court denied the motion to dismiss, ruling the action properly was one for unlawful detainer and that the court could consider ownership for the purpose of determining possession pursuant to Section 33, Batas Pambansa Blg. 129. The court denied the plaintiff’s motion for summary judgment on the ground that the answer specifically denied material allegations and set up affirmative defenses and that the court’s function on a motion for summary judgment was only to determine whether there was an issue of fact to be tried.

Supreme Court’s Legal Analysis on Summary Judgment

The Supreme Court analyzed the nature and purpose of summary judgment under Section 1, Rule 34, distinguishing it from judgment on the pleadings under Rule 19, and explaining that a summary judgment may be rendered when the movant shows that except as to damages there is no genuine issue as to any material fact. The Court held that the dispositive question is not merely whether issues are tendered by the answer but whether those issues are bona fide or are sham, fictitious, contrived, or set up in bad faith. Applying this standard, the Court found the defendants’ denials and defenses to be sham: their denials of personal circumstances and prior payments were implausible in light of longstanding occupancy and documentary proof; their professed ignorance of letters they authored was ineffectual as a denial; and their affirmative defense of ownership based on a separate annulment action in which they were not parties was tenuous, conjectural, and irrelevant to the ejectment action. The Court further observed that a tenant is estopped from denying the landlord’s title at the inception of the tenancy, reinforcing the lack of a genuine factual issue.

Remedy and Appropriateness of Extraordinary Writs

The Court explained the proper remedial vehicle for correcting the respondent Judge’s action. It stated that mandamus issues only to compel performance of a mandatory, ministerial duty and that the decision to grant or deny summary judgment is within the trial court’s discretion and therefore ordinarily not subject to mandamus. The Court found, however, that the respondent Judge had committed a grave abuse of discretion in denying the summary judgment. It held that the writ of certiorari would lie to correct such abuse. The Court also addressed the prudential question of original resort to the Supreme Court for extraordinary writs and emphasized that the Supreme Court’s original jurisdiction should be sparingly exercised and generally reserved for matters not controllable by the Court of Appeals or Regional Trial Courts; nonetheless, the Court concluded that referring this action to the Regional Trial Court would work injustice given delay and the case’s pendency before this Court since 1986.

Disposition and Directions

The Supreme Court annulled and set aside the Municipal Trial Court orders dated April 15, 1986 and April 30, 1986 denying the motion for summary judgment and reconsideration. The respondent Judge was commanded forthwith to render a summary judgment in favor o

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