Batongbacal v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Veronica I. Batongbacal filed a complaint for ejectment against Antonio Asuncion, the predecessor-in-interest of the private respondents. Batongbacal alleged that she was the owner of a parcel of land in Valenzuela, Metro Manila, and that Asuncion had occupied a portion of it without her consent, constructing two houses thereon. Despite demands to vacate, Asuncion refused. The private respondents, through Antonio Asuncion, countered that the land was originally owned by Batongbacal's mother, Trinidad, who had leased a portion to Eugenia Contreras' mother. Eugenia, married to Antonio Asuncion, continued paying rent after Trinidad's death and inherited the house. Negotiations for Asuncion to purchase the property had previously failed. Procedural History: The Metropolitan Trial Court (MTC) initially dismissed Batongbacal's ejectment complaint, finding that Asuncion had not entered the property through stealth or strategy, but rather as a lessee. However, the MTC also ordered Asuncion to pay reasonable rentals. Batongbacal appealed to the Regional Trial Court (RTC), which initially dismissed the appeal, ruling that the MTC lacked jurisdiction because the complaint was filed more than one year after the demand to vacate. Subsequently, the RTC reconsidered and issued an amended decision ordering the defendants to vacate and pay rentals, finding that a demand to vacate was made on May 31, 1983, well within the one-year period. Private respondents then petitioned the Court of Appeals (CA), which reversed the RTC's amended decision, reinstating the MTC's dismissal of the ejectment case. The CA found that a lessor-lessee relationship existed and that Asuncion's possession was not one of forcible entry, nor was it transformed into illegal detainer under the circumstances, particularly in light of Batas Pambansa Blg. 25. The Petition: Petitioner Batongbacal seeks to annul the Court of Appeals' decision and resolution, arguing that the CA lacked jurisdiction to review the RTC's amended decision, asserting that the RTC's ruling had become final and unappealable under Section 45 of the Judiciary Act, as amended by R.A. No. 6031. She further contends that the CA abused its discretion by reversing the RTC decision based on B.P. Blg. 25, as she claims no lessor-lessee relationship existed between her and the private respondents. Additionally, she argues that the CA gravely abused its discretion by ignoring arguments raised in her motion for reconsideration, specifically that any verbal lease agreement was not binding on her and not perpetual. The petition is filed under Rule 45 of the Rules of Court.
Issue(s)
Whether the Court of Appeals had jurisdiction to review the Regional Trial Court's amended decision. Whether the Regional Trial Court erred in reversing its initial decision and ordering the ejectment of the defendants; and whether a lessor-lessee relationship existed. Whether Batas Pambansa Blg. 25 is applicable to the case.
Ruling
The petition is denied. The Supreme Court affirmed the decision of the Court of Appeals, holding that the appellate court had jurisdiction to review the RTC's amended decision and that the ejectment suit could not prosper.
Ratio Decidendi
On the jurisdiction of the Court of Appeals: The Supreme Court clarified that the petitioner misread Section 45 of the Judiciary Act of 1948, as amended by R.A. No. 6031. The prohibition was against ordinary appeals, not petitions for review to the Court of Appeals. The Court cited the Interim Rules and Guidelines Relative to the Implementation of the Judiciary Reorganization Act of 1981, which allowed petitions for review from Metropolitan Trial Courts to the Intermediate Appellate Court (now Court of Appeals). The Court also noted that the cited cases of Buenbrazo, Merino, and Que did not support the petitioner's claim that the RTC's decision was final and unappealable, as they dealt with the prohibition of ordinary appeals, not petitions for review. Therefore, the Court of Appeals had jurisdiction to entertain the petition for review filed by the private respondents. On the Regional Trial Court's reversal and the existence of a lessor-lessee relationship: The Supreme Court found that both the MTC and RTC had determined that a lessor-lessee relationship existed between the petitioner and the Asuncions. The RTC's initial finding that the complaint was filed beyond the one-year period was based on a demand letter in February 1981, but its amended decision considered a subsequent demand letter in May 1983, which was within the one-year period for ejectment cases. On the applicability of Batas Pambansa Blg. 25: The Court agreed with the Court of Appeals that even if the suit were considered unlawful detainer, it could not succeed because it was not anchored on any of the grounds provided in Batas Pambansa Blg. 25. The Court emphasized that the petitioner, as the successor-in-interest to her mother, merely stepped into her mother's shoes and was bound by the verbal lease agreement. Therefore, she could not eject the lessee except on the grounds enumerated in B.P. Blg. 25, which were not established in this case. The Court reiterated that Antonio Asuncion's entry was not by stealth or strategy, but as a tenant, and his possession, initially legal, was transformed into possession by tolerance only after the lessor-lessee relationship was terminated according to law, which did not happen here.
Main Doctrine
A petition for review to the Court of Appeals is a proper mode of appeal from a Regional Trial Court's decision in cases originally cognizable by Metropolitan Trial Courts, and is not barred by provisions prohibiting ordinary appeals. Furthermore, an ejectment suit based on forcible entry cannot prosper if the entry was not by stealth or strategy, and if a lessor-lessee relationship exists, the lessor or successor-in-interest cannot eject the lessee except on grounds provided by Batas Pambansa Blg. 25.