Municipality of Biñan, Laguna v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The Municipality of Biñan, Laguna, represented by its Mayor, sought to terminate a 25-year lease agreement with Jesus M. Garcia over a certain premises. The Municipality cited its pressing need to utilize the property for national and provincial offices. The lease agreement, however, contained a provision for a renewal of another 25 years at the lessee's option. Mr. Garcia asserted his right to renew the lease, contending that the original term had not yet expired and that he had exercised his option to extend it. 2. Procedural History: The Municipality initiated an ejectment case (unlawful detainer) against Mr. Garcia before the Municipal Trial Court (MTC) of Biñan, Laguna. The MTC ruled in favor of the Municipality, ordering Mr. Garcia to vacate the premises. Mr. Garcia appealed this decision to the Regional Trial Court (RTC) of Biñan, Laguna. While the appeal was pending, the Municipality filed a motion for execution pending appeal, which the RTC granted. Mr. Garcia then filed a petition for certiorari with the Court of Appeals (CA), assailing the RTC's order granting execution pending appeal. The CA set aside the RTC's order and, additionally, annulled the MTC's judgment, finding it contrary to the parties' agreement. The Municipality sought reconsideration, which was denied, leading to the present petition before the Supreme Court. 3. The Petition: The Municipality of Biñan filed a petition for review on certiorari with the Supreme Court, arguing that the Court of Appeals exceeded its jurisdiction. The Municipality contended that the CA should have confined its review solely to the RTC's order granting execution pending appeal, which was the specific issue raised in Mr. Garcia's petition for certiorari before the CA. The Municipality asserted that the CA improperly annulled the MTC's judgment, which was still pending appeal before the RTC and was not the subject of the certiorari petition. The Municipality argued that the CA's action constituted an overreach of its authority and usurped the appellate jurisdiction of the RTC.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in annulling the Municipal Trial Court's judgment on the merits when the petition for certiorari before it only assailed the order granting execution pending appeal. Whether the Municipal Trial Court committed a grave abuse of discretion or acted without jurisdiction in failing to conduct a preliminary hearing on the affirmative defenses raised by the private respondent before rendering judgment on the merits.
Ruling
The Supreme Court granted the petition, reversed and set aside the Court of Appeals' decision insofar as it annulled the Municipal Trial Court's judgment, and remanded the case to the Regional Trial Court for further proceedings.
Ratio Decidendi
On the Court of Appeals' authority to annul the MTC judgment: The Supreme Court held that the Court of Appeals, in a certiorari proceeding under Rule 65 concerning an incident in a case (the order granting execution pending appeal), exceeded its authority by ruling on the merits of the main case itself. The petition before the CA was limited to assailing the validity of the RTC's order of execution pending appeal. The allegation that the MTC judgment was improvidently issued was merely an additional argument to support the theory that execution pending appeal was not in order. The CA's pronouncements on the MTC judgment were considered ultra jurisdictio because that judgment was on appeal before the RTC, and the CA's authority was confined to the issue of whether the RTC committed grave abuse of discretion in issuing the order of execution. The CA usurped or preempted the appellate powers of the RTC. On the Municipal Trial Court's failure to conduct a preliminary hearing: The Supreme Court ruled that the RTC did not commit a grave abuse of discretion or exceed its jurisdiction in failing to conduct a preliminary hearing on the affirmative defenses raised by the private respondent. Section 5, Rule 15 of the Rules of Court allows for a preliminary hearing on grounds for dismissal set up as affirmative defenses, but the use of the word "may" indicates that such a hearing is not mandatory but rests on the sound discretion of the trial court. Furthermore, a preliminary hearing on an affirmative defense of failure to state a cause of action is not necessary, as the sufficiency of the allegations in the complaint must be determined from the face of the complaint itself, without considering extraneous matters or facts not alleged, which require evidence and await trial. The MTC's decision to proceed to judgment on the pleadings, after exchanges and position papers, was within its discretion, and any alleged error in its judgment was an error of judgment or procedure correctible by ordinary appeal, not by certiorari.
Main Doctrine
A petition for certiorari under Rule 65 is limited to correcting errors of jurisdiction, and cannot be used to correct errors of judgment or procedure which are correctible by ordinary appeal. Furthermore, a Court of Appeals, in a certiorari proceeding involving an incident in a case, cannot rule on the merits of the main case itself which is not on appeal before it.