Siasat v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Private respondent Genie Development Corporation (GDC) initiated an ejectment case against petitioners Victor Siasat and Jesus Ong in the Metropolitan Trial Court (MTC) of Makati. The MTC issued summons, which were duly served on the petitioners. However, the petitioners failed to file an answer within the reglementary period, leading to their declaration in default. Subsequently, the MTC rendered a decision against the petitioners, which became final and executory after no appeal was filed within the prescribed period. A writ of execution was issued, and the ejectment aspect of the decision was satisfied. The monetary aspect led to the levy of petitioners' personal properties, with an auction sale scheduled. 2. Procedural History: Following the levy of their properties, the petitioners filed a Petition for Relief from Judgment with the Regional Trial Court (RTC) of Makati, blaming their former counsel for the default and failure to appeal. The RTC issued a preliminary injunction to halt the auction sale and later ordered the release of the levied properties. GDC challenged these orders via a petition for certiorari before the Court of Appeals (CA), which annulled the RTC's orders, citing grave abuse of discretion. GDC then filed a motion for summary judgment with the RTC, arguing that the CA's decision resolved all material issues. The RTC granted the summary judgment. Petitioners appealed this summary judgment to the CA, which affirmed the RTC's decision in its entirety. Petitioners' subsequent motion for reconsideration was denied, leading to the present appeal to the Supreme Court. 3. The Petition: The petitioners seek review of the Court of Appeals' decision affirming the summary judgment rendered by the Regional Trial Court. They contend that genuine issues of material fact exist, precluding a summary judgment. The core of their argument revolves around whether the circumstances surrounding their default and failure to appeal, attributed to their former counsel, present a substantial and meritorious claim that should have been considered, rather than being resolved through a summary judgment based on the prior Court of Appeals ruling which they believe was premised on a misapprehension of facts.
Issue(s)
Whether there exist genuine issues of material facts constitutive of petitioners’ substantial and meritorious claim. Whether a petition for relief from judgment is a permissible pleading in an ejectment case governed by the Revised Rule on Summary Procedure.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals in toto.
Ratio Decidendi
On the issue of genuine issues of material facts: The Court reiterated the rule that in an appeal via certiorari, it may not review the factual findings of the Court of Appeals when supported by substantial evidence, as these findings are conclusive and binding. The Court listed ten recognized exceptions where it may review such findings, but found that the present case did not fall under any of them. The core of the dispute stemmed from an ejectment case, which is typically governed by the Revised Rule on Summary Procedure. The Court emphasized that the findings of fact by the appellate court were conclusive and binding, and the petitioners failed to demonstrate any of the exceptions that would warrant a review of these findings. On the permissibility of a petition for relief from judgment: The Court held that the case at bar arose from a simple ejectment case initiated in the Metropolitan Trial Court. It underscored that the Revised Rule on Summary Procedure covers all ejectment cases, irrespective of whether they involve questions of ownership. Crucially, under Section 19 of the Revised Rule on Summary Procedure, a petition for relief from judgment is explicitly listed as a prohibited pleading. Therefore, a party in an ejectment suit before the municipal trial court cannot file such a pleading in the regional trial court. This prohibition directly addresses the procedural avenue petitioners attempted to utilize, rendering their petition for relief from judgment procedurally infirm from the outset.
Main Doctrine
A petition for relief from judgment is a prohibited pleading under the Revised Rule on Summary Procedure and thus cannot be filed in a regional trial court in an ejectment case originating from the metropolitan trial court.