Vergara v. Suelto
REITERATIONFacts
1. The Antecedents: Domingo Vergara, Sr. initiated an ejectment suit against Manolito Guinoo, Romeo Montebon, and Porferio Cabase for illegal detainer. Vergara alleged that the respondents were month-to-month lessees of his commercial building, had defaulted on rent payments, and that he required the premises for his own use. The respondents, in their defense, denied Vergara's ownership of the building and claimed ownership of the land on which it stood, citing a regional trial court decision that declared the lot part of the public domain. They also asserted that their lease contracts were void and that they occupied the premises as owners. 2. Procedural History: After the Barangay conciliation failed, Vergara filed an ejectment suit in the Municipal Trial Court of Davao City. He subsequently filed a Motion for Summary Judgment, arguing that the respondents' defenses were sham and that no genuine issue of material fact existed. The respondents opposed this motion, arguing that genuine issues of fact regarding ownership and possession were raised and that the court lacked jurisdiction. The Municipal Trial Court denied both the motion to dismiss and the motion for summary judgment, stating that a trial on the merits was necessary. Vergara then filed a special civil action for mandamus with the Supreme Court, seeking to compel the Municipal Trial Court to grant his motion for summary judgment. 3. The Petition: The petitioner, Domingo Vergara, Sr., sought a writ of mandamus to compel the Municipal Trial Court to grant his motion for summary judgment. He argued that the respondents' defenses were sham and that the facts clearly established his right to eject them. The Supreme Court addressed two main issues: the appropriateness of summary judgment in this case and the propriety of directly filing a mandamus petition with the Supreme Court against a municipal court. The Court found that the respondents' denials and affirmative defenses were indeed sham and that a summary judgment was warranted. However, it clarified that mandamus was not the proper remedy to compel a discretionary act, but rather certiorari would lie to correct grave abuse of discretion. The Court also reiterated its policy against direct recourse for extraordinary writs, but made an exception in this case due to the prolonged delay and the need to avoid further injustice to the petitioner.
Issue(s)
Whether the appropriateness of a summary judgment was so self-evident as to make it a duty for the Trial Judge to grant the plaintiff's motion therefor. Whether the filing of an application for a writ of mandamus directly with the Supreme Court against a municipal trial court is proper, considering that the Court of Appeals and Regional Trial Courts also possess jurisdiction to issue such a writ.
Ruling
The Supreme Court annulled and set aside the orders of the respondent Judge denying the motion for summary judgment and the motion for reconsideration. The respondent Judge was commanded to forthwith render a summary judgment in favor of the petitioner (plaintiff) against the private respondents (defendants) and to direct immediate execution of the judgment. The Court held that the issues tendered by the defendants were sham and not genuine, making a summary judgment proper as a matter of right. Regarding the second issue, the Court reiterated its policy that direct resort to the Supreme Court for extraordinary writs should be exercised only when absolutely necessary or for serious and important reasons, but made an exception in this case due to the considerable delay and the extensive exchange of pleadings already undertaken.
Ratio Decidendi
On the propriety of summary judgment: The Court found that the respondent Judge committed a grave abuse of discretion in denying the motion for summary judgment. The defendants' answer, while appearing to deny material allegations and raise affirmative defenses, did not tender genuine issues. Their denials of personal circumstances and the plaintiff's ownership of the building were found to be sham, contradicted by written contracts, rental payments, and their own letters acknowledging the landlord-tenant relationship and their commitment to vacate. Their professed ignorance of their own joint letter was deemed palpable dishonesty. Furthermore, their claim of ownership over the land was considered tenuous, absurd, and irrelevant to the ejectment case, especially since they were estopped from disputing the plaintiff's title as lessees. The Court emphasized that the determination of whether issues are genuine or sham is crucial, and in this case, the issues were clearly sham, making a trial unnecessary and a waste of time. The respondent Judge's confusion between summary judgment and judgment on the pleadings was also noted. On the propriety of direct resort to the Supreme Court: The Court affirmed its policy that direct recourse to the Supreme Court for extraordinary writs should be limited to exceptional circumstances to preserve its role as a court of last resort. However, in this particular case, the Court decided to resolve the petition directly to avoid further delay and injustice to the petitioner, who had already been waiting for relief for many years since the case was filed in 1986. Applying the policy strictly by referring the case to the Regional Trial Court would have served no useful purpose and would have further prolonged the petitioner's predicament.
Main Doctrine
A summary judgment may be rendered if there is no genuine issue as to any material fact, even if the answer appears to tender issues, provided that such issues are sham, fictitious, or set up in bad faith. The determination of whether a summary judgment is proper rests in the sound discretion of the trial court, and its grave abuse of discretion in denying a proper motion for summary judgment may be corrected by certiorari.