Chua v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns an unlawful detainer case initiated by respondent Marilu Samaco against petitioner Purificacion Chua for non-payment of rentals, subleasing without authority, and termination of a month-to-month lease. The property in question, an apartment unit, was originally owned by Andres S. Flores and Ligaya Flores. Through a series of transactions, ownership eventually vested in Marilu Samaco and her husband. Petitioner Chua had been leasing the unit and initially filed a consignation of rentals case when the new owner, Samaco, began collecting rent. Samaco subsequently filed the ejectment suit. 2. Procedural History: The Metropolitan Trial Court (MeTC) consolidated the consignation and ejectment cases and ruled against petitioner Chua. This decision was appealed to the Regional Trial Court (RTC). While the appeal was pending, petitioner filed a motion to set aside the judgment and a petition for certiorari with the Court of Appeals (CA), which was dismissed. A subsequent petition to the Supreme Court (SC) was also denied. Meanwhile, the RTC affirmed the MeTC's ejectment judgment. Petitioner appealed this to the CA, which reversed the RTC and remanded the case for re-trial under regular procedure. After re-trial, the MeTC again ruled for Samaco, ordering Chua to vacate and pay back rentals and attorney's fees. The RTC sustained this decision. Petitioner then filed a petition for certiorari, prohibition, and mandamus with the CA to annul a writ of execution issued by the RTC. The CA dismissed this petition, affirming the RTC's decision. 3. The Petition: Petitioner seeks review of the CA's dismissal of her petition for certiorari, prohibition, and mandamus. She argues the CA erred by ruling on the merits of the main case, which was still pending reconsideration before the RTC, and by not considering alleged supervening events that made execution oppressive. She also contends the CA failed to rule on a motion for contempt. The petition before this Court raises issues regarding the CA's jurisdiction and the propriety of the writ of execution, particularly in light of a pending action for quieting of title and alleged changes in the parties' situations. The petitioner is arguing that the CA overstepped its jurisdiction by ruling on the merits of the main case when the petition before it was solely to annul the writ of execution.
Issue(s)
Whether the Court of Appeals committed ultra jurisdictio in rendering judgment on the merits of the main case when the petition before it was solely for certiorari to annul a writ of execution. Whether the issuance of the writ of execution was proper despite the pendency of a motion for reconsideration and alleged supervening events. Whether the filing of a motion for reconsideration with a defective notice of hearing tolled the period to appeal.
Ruling
The Supreme Court annulled and set aside the Court of Appeals' decision insofar as it prematurely affirmed the Regional Trial Court's decision on the merits. The Regional Trial Court's decision dated January 5, 1993, in Civil Cases Nos. 92-61101 and 92-61102 was considered final and executory, and the questioned order of the Regional Trial Court dated March 5, 1993, for the issuance of a writ of execution was affirmed. The temporary restraining order issued by the Supreme Court was lifted. Treble costs were imposed against the petitioner.
Ratio Decidendi
On the Court of Appeals' jurisdiction: The Supreme Court held that the Court of Appeals acted ultra jurisdictio in affirming the judgment on the merits of the ejectment and consignation cases. The petition elevated to the CA was solely for certiorari to annul the order for the issuance of a writ of execution. The decision on the merits had not been appealed to the CA, as petitioner was awaiting resolution of her motion for reconsideration with the RTC. Therefore, the CA's authority was confined to ruling on the propriety of the issuance of the writ of execution, not on the merits of the main case. The writ of certiorari is available only to correct errors of jurisdiction or grave abuse of discretion amounting to lack of jurisdiction, not errors of procedure or mistakes in findings of fact or conclusions. On the propriety of the writ of execution: Despite the CA exceeding its jurisdiction, the Supreme Court found that the RTC did not commit grave abuse of discretion or act in excess of its jurisdiction in issuing the writ of execution. This was because the petitioner failed to comply with the requisites for staying execution, namely, perfecting an appeal, filing a supersedeas bond, and making periodic deposits of rental payments. The petitioner did not deny failing to file the required supersedeas bond and deposit monthly rentals, nor did she show a valid excuse. The alleged supervening event of subsequent sale or transfer of ownership was not a valid ground to bar execution in an unlawful detainer case, as the sole issue in such cases is physical possession. The pendency of an action for quieting of title also does not divest the MeTC of its jurisdiction over the ejectment case. Furthermore, the petitioner's action for consignation against Marilu Samaco recognized Samaco's right to collect rentals, estopping petitioner from questioning her title. On the effect of the motion for reconsideration: The Supreme Court found the petitioner's joint motion for reconsideration of the RTC's decision to be pro forma. It merely reiterated issues already passed upon and did not comply with the requirements of Section 2, Rule 37, in relation to Rule 15 of the Rules of Court. Crucially, the notice of hearing was directed to the clerk of court, not to the parties, which is a fatal defect violating Sections 4 and 5 of Rule 15. Such a violation means the motion did not toll the running of the period to appeal. Consequently, the decision of the RTC became final and executory, making execution a matter of right for the prevailing party.
Main Doctrine
The Court of Appeals acted ultra jurisdictio in affirming the judgment on the merits of an ejectment case when the petition before it was solely for certiorari to annul a writ of execution. However, despite the excess of jurisdiction, the Supreme Court found no grave abuse of discretion in the issuance of the writ of execution as the judgment had become final and executory, and the petitioner failed to comply with the requisites for staying execution.