Ho v. Lacsa
REITERATIONFacts
1. The Antecedents: Respondent Pedro S. Lacsa filed unlawful detainer and ejectment cases against petitioners Leoncio Ho and Wayne Hosin Cham. The Metropolitan Trial Court (MTC) ruled in favor of Lacsa, ordering the petitioners to vacate the premises and pay back rentals, interest, attorney's fees, and costs. This decision was initially affirmed by the Regional Trial Court (RTC). 2. Procedural History: Following the RTC's affirmation, petitioners filed a motion for reconsideration, alleging a typographical error in the date of receipt of the decision. The RTC, after reconsideration, set aside its previous decision and ruled in favor of the petitioners, ordering the respondent to pay damages and attorney's fees. The respondent moved for reconsideration and inhibition, leading to the judge's inhibition and the re-raffling of the case. A new RTC judge granted the respondent's motion for reconsideration, reinstating the original RTC decision that affirmed the MTC ruling. This order became final and executory. Instead of appealing this order, petitioners filed a special civil action for certiorari with the Court of Appeals (CA). 3. The Petition: The Court of Appeals dismissed the petitioners' special civil action for certiorari and their subsequent motion for reconsideration. The petitioners are now before the Supreme Court on a petition for review on certiorari, arguing that the CA erred in its conclusions regarding the timeliness of their motion for reconsideration before the RTC and the applicability of the rule disallowing tenants from disputing their landlord's title. They also contend that the CA erred in finding that the RTC had jurisdiction to set aside its own earlier order and render a new decision. The Supreme Court is asked to review these CA rulings.
Issue(s)
Whether the Court of Appeals erred in concluding that the Motion for Reconsideration of the defendant tenants of the Decision dated June 21, 1995 of the Assisting Judge of Branch 39 was filed out of time. Whether the Court of Appeals erred in concluding that even if the said Decision is not yet final, the Motion for Reconsideration cannot be allowed without violating the rule disauthorizing a tenant from disputing the title of his landlord as a conclusive presumption. Whether the RTC had jurisdiction to set aside its own Order dated May 31, 1996, and to render the Decision dated June 4, 1996.
Ruling
The petition is DENIED for utter lack of merit. Double costs against petitioners.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in concluding that the Motion for Reconsideration was filed out of time: The Supreme Court clarified that the Court of Appeals did not rule on the timeliness of the motion for reconsideration from the RTC Decision dated June 21, 1995. Instead, the CA's main contention was whether the RTC had jurisdiction to set aside its own earlier order and render a subsequent decision. The CA found that the RTC, through Judge Lopez, acted within its jurisdiction when it reconsidered the case following Judge Vega's inhibition and the re-raffling of the case. The CA viewed Judge Lopez's action not as a reversal of a co-equal court's decision but as a continuation of the same jurisdiction over the cases. Therefore, the petitioners' arguments based on the alleged untimeliness of the motion for reconsideration were deemed flawed as they were not the basis of the CA's decision. On the issue of whether the Motion for Reconsideration can be allowed without violating the rule disauthorizing a tenant from disputing the title of his landlord: The Supreme Court noted that the CA did not rule on the admissibility or merit of the motion for reconsideration in relation to the tenant-landlord rule. The CA's focus was on the procedural propriety of the RTC's actions. The petitioners' arguments on this point were therefore considered misplaced as they did not align with the CA's actual findings and rulings. The core issue before the CA was the jurisdiction of the RTC to act on the case after a re-raffling due to inhibition. On the issue of whether the RTC had jurisdiction to set aside its own Order dated May 31, 1996, and to render the Decision dated June 4, 1996: The Supreme Court affirmed the CA's ruling that the RTC, through Judge Lopez, had jurisdiction. The CA reasoned that when a judge inhibits himself, the case is re-raffled, and the new judge takes cognizance of the case at whatever stage it was. This is not a reversal of a decision by a co-equal court but a continuation of the same jurisdiction. The re-raffling of the cases to Judge Lopez was proper following Judge Vega's inhibition, and Judge Lopez thus acquired jurisdiction over the cases in place of the former judge. Consequently, the subsequent order of the MTC issuing a writ of execution and the sheriff's actions were also deemed proper.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for a timely appeal or petition for review. Failure to perfect an appeal within the reglementary period renders the judgment final and executory, making it immutable and unalterable.