Cue v. Dolla
REITERATIONFacts
The Antecedents: Defendant Pilar Dolla was the lessee of two doors of a building owned by plaintiff Elisa Medina Cue since August 1958, on a month-to-month basis, for P1,500.00 per month, utilized for her bakery business. On February 14, 1966, plaintiff sold the building to Philippine Savings Bank (PSB) for P700,000.00, with a covenant to deliver possession free from tenants by May 31, 1966, failing which P80,000.00 would be forfeited. Plaintiff informed defendant of the sale and requested her to vacate by May 31, 1966, which defendant refused. Plaintiff then notified defendant of the lease termination as of March 1966 and demanded she vacate by March 31, 1966. Procedural History: Upon defendant's failure to vacate, plaintiff filed an unlawful detainer suit. The city court rendered judgment allowing defendant to occupy for one year from the judgment date, provided rentals were paid, and ordered her to vacate thereafter. Both parties appealed to the Court of First Instance (CFI). Before trial in the CFI, PSB filed a motion to intervene, seeking to join plaintiff's prayer for ejectment and demanding P14,000.00 per month as reasonable compensation for use and occupation. The CFI denied PSB's motion to intervene, citing failure to intervene in the city court and the introduction of new issues. PSB's motion for reconsideration was also denied. PSB appealed directly to the Supreme Court. The Petition: Philippine Savings Bank (PSB) appealed the CFI's denial of its motion to intervene.
Issue(s)
Whether intervention by the Philippine Savings Bank (PSB) is permissible in a case on appeal from the city court to the Court of First Instance before trial de novo. Whether the intervention, specifically PSB's increased demand for reasonable compensation for use and occupation, would change the nature of the cause of action or create new issues. Whether the trial court prudently exercised its discretion in denying PSB's motion for intervention.
Ruling
The Supreme Court reversed and set aside the orders of the CFI denying PSB's intervention and motion for reconsideration, directing the CFI to allow the intervention and admit PSB's complaint in intervention. Costs were against defendant Pilar Dolla.
Ratio Decidendi
On Issue 1: The Supreme Court held that intervention is permissible in a case on appeal from the city court to the Court of First Instance before trial de novo. The Court reasoned that under Section 9, Rule 40 of the Rules of Court, a perfected appeal from the city court to the Court of First Instance operates to vacate the judgment of the city court. This means that all previous proceedings, including the judgment, are considered non-existent, and the action stands for trial de novo in the Court of First Instance, as though it had never been tried before and was originally commenced there. Since the trial in the Court of First Instance is essentially a fresh proceeding where evidence must be presented anew, Section 2, Rule 12 of the Rules of Court, which allows intervention "before or during a trial," applies to this de novo trial. Therefore, intervention sought before the commencement of this de novo trial is timely and proper. On Issue 2: The Supreme Court ruled that the intervention, even with the increased demand for reasonable compensation, would not change the nature of the cause of action or create new issues. The Court noted that the intervenor, PSB, merely joined hands with the plaintiff, Elisa Medina Cue, in seeking the ejectment of the defendant, Pilar Dolla, which remains the fundamental cause of action. Citing Mapua vs. Suburban Theaters, Inc., the Court reiterated that in an ejectment case, a money claim for damages or reasonable compensation for occupancy is merely incidental to and flows from the main cause of action. The Court emphasized that it is the nature of the action, not the amount of rentals or damages, that confers jurisdiction on the inferior court, thus an increase in the amount sought does not alter the underlying ejectment action. On Issue 3: The Supreme Court concluded that the trial court's discretion in denying intervention was not prudently exercised. The Court considered PSB's compelling reasons for intervention, including its desire to obtain prompt possession of the premises to construct a branch office, its significant investment in the property (P700,000.00), and the prejudice it would suffer from delay in the delivery of the premises as stipulated in its deed of sale. Given these circumstances, the Supreme Court found that denying PSB, the new owner with a direct interest in the property and its immediate possession, the opportunity to intervene constituted an abuse of discretion, thereby warranting the reversal of the lower court's orders.
Main Doctrine
Intervention may be allowed in a case appealed to the Court of First Instance and set for trial de novo, even if not sought in the inferior court, provided it is filed before the trial commences and does not introduce entirely new issues unrelated to the original cause of action. The discretion to allow intervention must be exercised prudently, considering the intervenor's investment, potential prejudice from delay, and the nature of the action.