Vda. de Guia v. Veloso
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a property that was the subject of a mortgage between petitioners Belen L. Vda. de Guia and Melba O. Valenzuela, and respondent Republic Mines & Investment Co., Inc. The petitioners failed to pay the mortgage and subsequently failed to redeem the property, leading to its foreclosure and the consolidation of title in favor of the Company. 2. Procedural History: Petitioners filed two actions seeking to recover the property, one for rescission of the mortgage and another for a declaration of premature foreclosure, both of which were dismissed by the trial court and later affirmed by the Court of Appeals. Concurrently, the Company filed an ejectment suit due to the petitioners' continued refusal to vacate the property. The City Court ruled in favor of the Company, ordering the petitioners to vacate and pay monthly rentals. This decision was affirmed by the Court of First Instance, which increased the monthly rentals. Meanwhile, the Supreme Court dismissed the petitioners' petition for review of the Court of Appeals' dismissal of their earlier actions. 3. The Petition: The petitioners filed a petition for certiorari with the Supreme Court, alleging grave abuse of discretion by the trial judge in conducting proceedings on appeal and issuing the writ of execution. They contended that their constitutional rights were violated due to a lack of notice of pleadings after the Company appealed to the Court of First Instance, and that the trial court failed to consider their pending cases before the Court of Appeals. The Supreme Court, however, found that the petitioners had received notice of the appeal and other relevant pleadings, and that the trial court had taken judicial notice of the pending cases. The Court ultimately dismissed the petition, finding no grave abuse of discretion and affirming the lower court's decision.
Issue(s)
Whether the respondent trial court committed grave abuse of discretion in increasing the amount of rental to P3,000.00. Whether the petitioners were denied due process.
Ruling
The petition is dismissed for lack of merit. The temporary restraining order issued by the Court is dissolved. The questioned decision of the respondent court is affirmed.
Ratio Decidendi
On the issue of grave abuse of discretion in increasing rentals: The Supreme Court ruled that the respondent trial court did not commit grave abuse of discretion in increasing the monthly rentals from P600.00 to P3,000.00. The Court noted that the Company only appealed the rental amount fixed by the City Court. The increase was based on the property's area (677.20 square meters) and its location in a commercial district. Furthermore, the trial court considered testimony from petitioner Belen Lopez Vda. de Guia regarding previous lease offers from Filoil Corporation (P2,500.00/month, rejected by petitioner who asked for P3,500.00) and Mercury Drug Corporation (P3,000.00/month for building construction). This evidence supported the reasonableness of the P3,000.00 monthly rental. On the issue of denial of due process: The Supreme Court found the petitioners' allegation of denial of due process to be without proof. The records clearly showed that the petitioners' counsel received several pleadings, including the Company's "Notice of Appeal," the trial court's "Order" setting a period for filing memoranda, and the Company's "Memorandum." Therefore, it could not be said that the trial court violated the petitioners' right to due process, amounting to grave abuse of discretion. The Court also noted that the trial court took judicial notice of the cases filed by the petitioners against the Company, which were pending before the Court of Appeals, when it increased the rental. The Court reiterated that a writ of certiorari issues for the correction of errors of jurisdiction only or grave abuse of discretion amounting to lack or excess of jurisdiction, and it cannot be used as a general utility tool. Finally, the Court emphasized that since the respondent Company had secured title and consolidated ownership over the property, it was just for a writ of possession to be issued in its favor, citing previous rulings that a writ of possession can be issued after the redemption period has lapsed, especially when a new title has been issued to the purchaser.
Main Doctrine
The Supreme Court affirmed the decision of the Court of First Instance, holding that the trial court did not commit grave abuse of discretion in increasing the monthly rentals and in issuing the writ of possession, as the petitioners' constitutional rights were not violated and the respondent company had secured title over the property.