Spouses Gonzaga v. Spouses Abagat
REITERATIONFacts
The Antecedents: Respondents Spouses Abagat filed a complaint for recovery of possession of Lot 11, Block No. 15, TCT No. 128186, alleging ownership. They claimed to have owned a hut on the lot, which was later occupied and remodeled by Spouses Gregorio after a fire. Spouses Gregorio sold the house to Petitioners Spouses Gonzaga. Meanwhile, Respondent Alfonso Abagat secured a sales patent for the land. Spouses Abagat demanded petitioners vacate, which they refused. Procedural History: The Municipal Trial Court dismissed the ejectment case filed by Spouses Abagat against Spouses Gregorio for lack of jurisdiction. Petitioners filed a third-party complaint against Spouses Gregorio for indemnity. Spouses Gregorio intervened in the main case. The Regional Trial Court ruled in favor of Spouses Abagat, ordering petitioners and Spouses Gregorio to vacate and pay damages. The Court of Appeals affirmed the RTC decision. The Supreme Court reviewed the CA decision, focusing on whether the RTC and CA erred in not ordering Spouses Gregorio to refund the ₱90,000.00 paid by petitioners. The Petition: Petitioners sought review of the CA decision, arguing that the RTC and CA erred in not ordering the intervenors (Spouses Gregorio) to refund the ₱90,000.00 paid by petitioners for the house, as agreed upon in a Memorandum of Agreement. Petitioners contended that Spouses Gregorio admitted their liability in their pleadings.
Issue(s)
Whether the trial court and the Court of Appeals erred in not ordering the intervenors (Spouses Gregorio) to refund the ₱90,000.00 paid by the petitioners (Spouses Gonzaga) for the house. Whether the Supreme Court can grant relief not prayed for in the pleadings.
Ruling
The petition is denied due course. The assailed decision and resolution of the Court of Appeals are affirmed. Costs against the petitioners.
Ratio Decidendi
On the issue of refund by Spouses Gregorio: The Supreme Court held that the petitioners failed to file any pleading against the Spouses Gregorio for the enforcement of the deed of conditional sale, the deed of final and absolute sale, and the Memorandum of Agreement. Although a motion for leave to file a third-party complaint was filed, the prayer did not include a demand for the refund of ₱90,000.00. Furthermore, the motion was denied, and the petitioners did not assail this denial in the appellate court. Even after Spouses Gregorio intervened, petitioners failed to file a cross-claim for specific performance to recover the ₱90,000.00. Therefore, the trial court had no jurisdiction to render judgment ordering the intervenors to refund the amount. On the scope of relief: The Supreme Court reiterated that a judgment must be complete by itself and should not leave open any judicial question. However, the Court has no authority to grant relief beyond the scope of the pleadings and prayers of the parties. A party is entitled only to such relief consistent with and limited to that sought by the pleadings or incidental thereto. A trial court would be acting beyond its jurisdiction if it grants relief beyond the scope of the pleadings. The right of a party to recover depends on the scope of the pleadings, the issues made, and the law, not solely on the prayer. A judgment granting reliefs of a character not sought is void.
Main Doctrine
A court cannot grant relief beyond the scope of the pleadings and prayers of the parties. A party is entitled only to such relief consistent with and limited to that sought by the pleadings or incidental thereto. A judgment granting relief not sought is void.