Barrazona v. San-An Realty
REITERATIONFacts
The Antecedents: San-an Realty and Development Corporation (respondent) owns a building and leased portions thereof to Vangie Barrazona (petitioner) for a two-year period commencing July 15, 2001. Petitioner defaulted in paying monthly rentals starting August 2001. Procedural History: On May 14, 2002, respondent filed a Complaint for Collection of Sum of Money with Damages against petitioner. Petitioner filed a Motion to Dismiss, arguing that the RTC lacked jurisdiction as the allegations in the complaint indicated an ejectment case, cognizable by the MTC. The RTC, in an Order dated June 19, 2002, denied the Motion to Dismiss. The Petition: Petitioner filed a Petition for Certiorari, assailing the RTC's Order for allegedly committing grave abuse of discretion and for failing to state its legal basis. The respondent contended that the complaint was for collection of unpaid rentals, not ejectment, and that petitioner should have filed a motion for reconsideration.
Issue(s)
Whether the Regional Trial Court committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying petitioner's Motion to Dismiss. Whether the RTC's Order denying the Motion to Dismiss is unconstitutional for failing to state its legal basis.
Ruling
The petition is GRANTED. The Order dated June 19, 2002, issued by the RTC, Branch 61, Baguio City, in Civil Case No. 5238-R, is ANNULLED and SET ASIDE.
Ratio Decidendi
On the issue of Grave Abuse of Discretion: The Supreme Court held that the RTC acted with grave abuse of discretion in denying the petitioner's motion to dismiss. The Court reiterated the rule that jurisdiction over the subject matter is determined by the allegations in the complaint, irrespective of the plaintiff's entitlement to recover. The Court found that paragraph 5 of the complaint, which stated that the plaintiff had demanded the defendant to pay overdue rentals and to vacate the premises, clearly indicated that the action was for ejectment. Ejectment cases are within the exclusive jurisdiction of the Municipal Trial Court (MTC), not the Regional Trial Court (RTC). Therefore, the RTC's denial of the motion to dismiss, which was based on lack of jurisdiction, constituted grave abuse of discretion. On the issue of the RTC's Order lacking legal basis: The Supreme Court found that the RTC's Order denying the motion to dismiss violated the Constitution and procedural rules by failing to state the facts and the law on which it was based. The Court emphasized that trial courts should not issue minute orders or resolutions without stating the reasons for their dispositions. Section 3, Rule 16 of the 1997 Rules of Civil Procedure requires that resolutions disposing of a motion to dismiss shall state clearly and distinctly the reasons therefor. The Court noted that such perfunctory dispositions can cause difficulty for the aggrieved party and the appellate court. While an order denying a motion to dismiss is generally interlocutory, certiorari is a proper remedy if the denial is without or in excess of jurisdiction, as in this case.
Main Doctrine
A Regional Trial Court commits grave abuse of discretion amounting to lack or excess of jurisdiction in denying a motion to dismiss a complaint for collection of sum of money when the allegations in the complaint clearly indicate that the action is for ejectment, which falls under the exclusive jurisdiction of the Municipal Trial Court.