Santiago v. Guadiz, Jr.
REITERATIONFacts
The Antecedents: Petitioner Cynthia Santiago leased commercial space from Alyssia International Trade Corp. (lessor) for a term of one year commencing March 15, 1987, with a monthly rental of P2,650.00. On January 22, 1988, the lessor filed an ejectment case against the lessee for non-payment of rentals. A writ of preliminary attachment was granted, and sheriff attached office equipment, paralyzing the lessee's operations. Procedural History: The lessee received summons on January 24, 1988, with notice of hearing under the Rule on Summary Procedure. On January 29, 1988, they moved for a 10-day extension to file their answer, citing pressure of work. On February 8, 1988, the Metropolitan Trial Court (MTC) rendered judgment ordering the defendants to vacate, pay accrued rentals and attorney's fees, as the answer was filed late on February 11, 1988. The MTC decision was affirmed by the Regional Trial Court (RTC) on July 18, 1988, which increased attorney's fees. A writ of execution was issued, and petitioner Cynthia Santiago's bank deposit was garnished. Petitioners sought relief from the Supreme Court, alleging grave abuse of discretion by the respondent judges. The Petition: Petitioners claim denial of due process for the MTC's decision without considering their answer, lack of jurisdiction due to no prior demand to vacate, irregularity in the attachment of properties belonging to a third party, and improper service of the writ of execution. They also question the withdrawal of their deposit by an unauthorized person.
Issue(s)
Whether the Metropolitan Trial Court committed grave abuse of discretion in rendering judgment based on the complaint without considering the late-filed answer. Whether the Metropolitan Trial Court had jurisdiction over the ejectment case despite the alleged lack of prior demand to vacate and pay accrued rentals. Whether the writ of attachment was validly issued and executed, particularly concerning properties claimed by a third party. Whether the writ of execution was validly enforced without prior formal service of the final decision. Whether the order allowing the withdrawal of deposits was irregular.
Ruling
The Supreme Court denied the petition, affirming the decision of the Regional Trial Court with modification regarding the computation of liabilities. The Court held that the petitioners' motion for extension to file an answer was a prohibited pleading under the Rule on Summary Procedure, and its late filing justified the MTC's decision based on the complaint. The Court found that the lessor had made the requisite demands and that the attachment was valid. It also ruled that the petitioners had actual notice of the decision, negating their claim of lack of due process regarding the writ of execution. The withdrawal of deposits was deemed valid under Section 8 of Rule 70.
Ratio Decidendi
On the denial of due process and the late filing of the answer: The Court reiterated that under Section 4 of the Rule on Summary Procedure, a defendant must answer within ten (10) days from service of summons. Section 5 explicitly states that failure to answer within the reglementary period allows the court, motu proprio or upon motion, to render judgment based on the facts alleged in the complaint. The petitioners' motion for extension was a prohibited pleading under Section 15 of the same Rule, and thus did not suspend the period to file their answer. Their subsequent filing of the answer eight days beyond the allowed period rendered it tardy and correctly disregarded by the MTC. Therefore, the petitioners cannot claim denial of due process when they failed to comply with the mandatory procedural requirements of the Rule on Summary Procedure. The Court distinguished this case from Zenith Films, Inc. vs. Herrera, emphasizing that the latter case did not involve the Rule on Summary Procedure and the court therein failed to observe its own order regarding the hearing date, unlike in the present case where a reasonable period was given for filing the answer. On the jurisdiction of the Metropolitan Trial Court: The Court held that the Metropolitan Trial Court had jurisdiction. The petitioners' assertion that no demand to vacate and pay accrued rentals was made was unsubstantiated because their answer, which would have been the proper venue to raise such a defense, was filed tardily. Under Section 5 of the Rule on Summary Procedure, the judge is justified in relying on the allegations in the complaint if no answer is filed on time. Furthermore, the private respondent attached a letter to the complaint demanding that the petitioners vacate the leased premises and pay accrued rentals, the veracity of which was never refuted by the petitioners due to their failure to file their answer on time. Thus, the requisite demands were presumed to have been made. On the validity of the attachment order: The Court found the attachment order to be regular. The private respondent had filed the required affidavit and bond in accordance with Sections 3 and 4 of Rule 57 of the Rules of Court prior to the issuance of the writ. Regarding the attachment of properties claimed by Tri-Tract Services, the Court noted that petitioner Edistio Fe. Santiago was the president and chairman of the board of said corporation and had indicated his address at the disputed leased premises. As he was an occupant of the premises without the lessor's consent and a co-defendant in the ejectment case, properties found in the premises that he claimed as his own were subject to attachment. The Court was not persuaded by the argument that the properties belonged to a separate corporation, given the petitioner's involvement and his use of the leased premises. On the validity of the writ of execution and notice: The Court ruled that while formal service of a judgment is generally necessary, it was not required in this case. The petitioners had filed a motion for reconsideration of the RTC decision, which indicated they were already aware of the decision. Therefore, they could not invoke due process based on a lack of formal notice, as actual notice prevailed over the absence of formal service. The garnishment order was lifted due to the sufficiency of the properties already attached to answer for the petitioners' liabilities. On the withdrawal of deposits: The Court found the order allowing Atty. Mila T. Fideris to withdraw deposits to be resoluble under Section 8 of Rule 70 of the Rules of Court. The reason for the withdrawal was the petitioners' failure to pay rentals for February and March 1988 on time. Citing Carbungco v. Amparo, the Court emphasized that the provision requiring deposit of rentals within the first ten days of the succeeding month is mandatory. Failure to comply leaves the court with no discretion to extend the period or relieve the appellant of the consequences. The petitioners' argument that the attached properties or their cash deposit were sufficient was irrelevant; they should have filed a motion to lift the attachment if they believed it was excessive. The fact that Atty. Fideris was not a party to the action did not render the order irregular, as she was authorized by the plaintiff to receive the withdrawal and was acting for a party.
Main Doctrine
A motion for extension of time to file an answer in cases governed by the Rule on Summary Procedure is a prohibited pleading and does not suspend the period to file the answer. Failure to file the answer within the reglementary period justifies the court in rendering judgment based on the facts alleged in the complaint.