Guerrero v. Domingo
REITERATIONFacts
The Antecedents: Spouses Alvin and Mercury Guerrero (spouses Guerrero) entered into a Contract to Sell with Pilar Development Corporation (PDC) for a property. PDC filed an Unlawful Detainer case against the spouses Guerrero before the Metropolitan Trial Court (MeTC) of Las Piñas City, alleging non-payment and subsequent cancellation of the Contract to Sell. The spouses Guerrero filed an Answer with Reservation, arguing that the MeTC could not adjudicate claims involving contract extinguishment and ejectment simultaneously. Procedural History: The spouses Guerrero filed a Petition for Prohibition with the Regional Trial Court (RTC) of Las Piñas City, seeking to quash the MeTC complaint. The MeTC ruled in favor of PDC, holding that it had jurisdiction over the unlawful detainer case. The spouses Guerrero appealed this decision to the RTC. Meanwhile, the RTC-Branch 201 denied their Petition for Prohibition. Subsequently, the RTC-Branch 197 dismissed the spouses Guerrero's appeal from the MeTC decision due to their failure to file a Memorandum of Appeal and comply with court orders. The records were returned to the MeTC. The Petition: The spouses Guerrero filed a Petition for Review on Certiorari with the Supreme Court, assailing the RTC-Branch 201's Order denying their Petition for Prohibition. They reiterated their argument that the MeTC lacked jurisdiction due to the joinder of an action beyond pecuniary estimation (contract extinguishment) with an unlawful detainer action.
Issue(s)
Whether the Petition for Prohibition was the proper remedy. Whether the Metropolitan Trial Court had jurisdiction over the unlawful detainer case, considering the cancellation of the Contract to Sell. Whether the spouses Guerrero had plain, speedy, and adequate remedies in the ordinary course of law.
Ruling
The Supreme Court denied the Petition for Review on Certiorari and affirmed the Decision of the Regional Trial Court, Branch 201 of Las Piñas City. The Court held that prohibition was not the proper remedy as the acts sought to be prevented had already become fait accompli, and the spouses Guerrero had other adequate remedies available.
Ratio Decidendi
On the propriety of the Petition for Prohibition: The Court reiterated the principle that prohibition is a preventive remedy and does not lie to restrain an act that has already been accomplished. In this case, the Contract to Sell had already been cancelled before the filing of the unlawful detainer complaint, and the MeTC had already rendered a decision. Furthermore, the spouses Guerrero's appeal from the MeTC decision had also been dismissed. Therefore, the act sought to be prohibited, namely the MeTC's hearing of the case, was already a fait accompli. The Court also noted that the Petition for Prohibition was filed after the MeTC had already disposed of the case, rendering the remedy inappropriate. On the jurisdiction of the Metropolitan Trial Court: The Court found that the MeTC correctly assumed jurisdiction over the unlawful detainer case. The primary issue in an unlawful detainer case is physical possession, and any finding on the ownership or validity of a contract is merely incidental to the determination of the right to possess. The MeTC's ruling that the case was an unlawful detainer, cognizable by it, was consistent with the allegations and reliefs prayed for in the complaint. The spouses Guerrero's insistence on the invalidity of the contract cancellation could have been asserted in a separate civil action or as a defense in the ejectment suit, without necessarily divesting the MeTC of its jurisdiction over the issue of possession. On the availability of other remedies: The Court emphasized that to avail of the extraordinary writ of prohibition, petitioners must have no appeal, nor any plain, speedy, and adequate remedy in the ordinary course of law. In this case, the spouses Guerrero had available remedies. They could have filed a Motion to Dismiss before the MeTC on the ground of lack of jurisdiction, as provided under Section 13, Rule 70 of the 1997 Rules of Civil Procedure. Alternatively, they could have raised the issue of jurisdiction as an affirmative defense in their Answer, which they did. However, they failed to actively participate in the MeTC proceedings and subsequently lost their appeal due to their own negligence. The Court concluded that prohibition should not lie when petitioners could have resorted to other remedies that were lost due to their own neglect.
Main Doctrine
Prohibition does not lie to restrain an act that is already a fait accompli, especially when the petitioner had plain, speedy, and adequate remedies in the ordinary course of law, such as a Motion to Dismiss or raising the issue as an affirmative defense in the Answer.