Spouses Ipapo v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Petitioners leased a property to private respondent and her late husband. Private respondent paid rentals for two years but subsequently desisted from paying. Petitioners sent a demand letter for payment of arrears and surrender of the property, which private respondent refused. Procedural History: Petitioners filed an ejectment case. Private respondent alleged justification for non-payment, claiming petitioners refused to execute a lease contract with an option to buy. The Municipal Trial Court ruled in favor of petitioners. The Regional Trial Court affirmed this decision. The Intermediate Appellate Court, however, remanded the case to the Municipal Trial Court for reopening of trial and introduction of additional evidence by both parties. Petitioners filed a motion for reconsideration of this decision, which was denied by the Intermediate Appellate Court for being filed out of time and for lack of merit. The Petition: Petitioners seek review of the Intermediate Appellate Court's decision remanding the ejectment case and its resolution denying their motion for reconsideration.
Issue(s)
Whether the Intermediate Appellate Court gravely erred and abused its discretion in remanding the ejectment case to the trial court for further reception of additional evidence on an issue already foreclosed in a previous related civil case. Whether the Intermediate Appellate Court erred in denying petitioners' motion for reconsideration on the ground that it was filed out of time.
Ruling
The petition is granted. The decision of the Intermediate Appellate Court is reversed and set aside. The decision of the Regional Trial Court, affirming the Municipal Trial Court's decision (with modification as to attorney's fees), is reinstated as the judgment in this case. This decision is immediately executory.
Ratio Decidendi
On the propriety of remanding the case for further reception of evidence: The respondent appellate court gravely erred and abused its discretion by directing the remand of the ejectment case for further reception of additional evidence on an issue which had already been foreclosed in a previous related Civil Case No. 1693-V-82. Ejectment cases are intended to be expeditiously resolved. The municipal trial court and the regional trial court had already ruled in favor of the lessors-petitioners. Remanding the case would be a waste of effort and time, prolonging the unjustified stay of the private respondent despite her nonpayment of rentals, and would prejudice the petitioners. The issue of the alleged verbal option to buy was already ruled upon in favor of the petitioners in a previous civil case before the Court of First Instance of Bulacan, which found that the Statute of Frauds barred the enforcement of an oral contract for the sale of real property absent a written note or memorandum, and that any construction was pursuant to the lease agreement, not partial performance of an option to buy. On the denial of the motion for reconsideration: The Intermediate Appellate Court's denial of petitioners' motion for extension of time to file a motion for reconsideration, based on the ruling in Habaluyas Enterprises vs. Japson, was improper. While the Habaluyas case initially disallowed motions for extension of time to file motions for reconsideration in lower courts, a subsequent clarificatory resolution modified this rule. The clarificatory resolution stated that the strict enforcement of the rule would commence only one month after May 30, 1986, i.e., effective June 30, 1986. Petitioners' motion for extension was filed on September 27, 1985, prior to the effective date of strict enforcement. Therefore, the denial of the motion for extension, and consequently the motion for reconsideration, based on a strict application of a rule that had not yet become fully effective, was erroneous. The interest of justice would be better served by not depriving parties of their right to appeal or seek reconsideration based on a procedure not expressly prohibited or allowed at the time.
Main Doctrine
The Intermediate Appellate Court gravely erred in remanding an ejectment case for further reception of evidence on an issue already foreclosed in a previous civil case, and in denying a motion for reconsideration based on a strict application of a rule on extensions of time that had not yet become fully effective.