Regulus Development v. Dela Cruz
REITERATIONFacts
The Antecedents: Regulus Development, Inc. (petitioner) is the owner of San Juan Apartments. Antonio dela Cruz (respondent) leased two units of the apartment complex starting in 1993 and 1994, with monthly lease agreements subject to automatic renewal unless terminated by written notice. The petitioner sent a notice to terminate the lease agreements. Upon the respondent's refusal to vacate the premises, the petitioner filed an ejectment case before the Metropolitan Trial Court (MTC) of Pasay City. Procedural History: The MTC ruled in favor of the petitioner, ordering the respondent to vacate and pay accrued rentals. The Regional Trial Court (RTC) affirmed the MTC's decision. However, the Court of Appeals (CA), in CA-G.R. SP No. 69504, reversed the lower courts' rulings and dismissed the ejectment case, a decision that became final and executory. Subsequently, the petitioner sought to withdraw rentals consigned by the respondent with the RTC. The RTC, in its July 25, 2003 and November 28, 2003 orders, allowed the withdrawal of these consigned rentals, citing equity jurisdiction. The respondent challenged these orders via certiorari before the CA (CA-G.R. SP No. 81277), which dismissed the petition, holding that the RTC orders were issued pursuant to its equity jurisdiction. This CA decision was affirmed by the Supreme Court in G.R. SP No. 171429. The petitioner then sought to execute the RTC orders, leading to the levy on the respondent's real property. The respondent challenged this levy before the CA (CA-G.R. SP No. 105290), which reversed the RTC's orders, ruling that the RTC lacked jurisdiction to levy on the respondent's property as the ejectment case had already been dismissed and its execution should have been handled by the MTC. The Petition: The petitioner filed this petition for review on certiorari under Rule 45 of the Rules of Court, seeking to overturn the CA's decision in CA-G.R. SP No. 105290. The petitioner argues that the RTC's orders for the release of consigned rentals and the subsequent levy on the respondent's property were valid exercises of its equity jurisdiction, independent of the dismissed ejectment case. Furthermore, the petitioner contends that the respondent's petition before the CA had become moot and academic due to the auction sale and subsequent redemption of the property. Lastly, the petitioner asserts that the respondent's petition before the CA should have been dismissed for a formal defect in the verification and certification against forum shopping. The core issue presented is whether the RTC possessed the jurisdiction to order the levy on the respondent's real property.
Issue(s)
Whether the RTC had jurisdiction to order the levy on the respondent's real property. Whether the respondent's petition before the CA was moot and academic due to the redemption of the property. Whether the CA petition should have been dismissed for lack of a notarial seal on the Verification and Certification against Forum Shopping.
Ruling
The Supreme Court granted the petition. It reversed and set aside the decision and resolution of the Court of Appeals, and reinstated the orders of the Regional Trial Court.
Ratio Decidendi
On the issue of jurisdiction to levy on real property: The Supreme Court held that the RTC had jurisdiction to order the levy on the respondent's real property. The Court clarified that the RTC orders allowing the withdrawal of consigned rentals and the levy on real property were issued in the exercise of its equity jurisdiction, independent of the ejectment case originally filed with the MTC. The Court emphasized that equity jurisdiction aims to provide complete justice in cases where the law is inflexible, and its purpose includes preventing unjust enrichment and ensuring restitution. The levy on the respondent's property was made pursuant to the RTC orders dated July 25, 2003, and November 28, 2003, which were themselves issued in the exercise of equity jurisdiction to satisfy amounts due under the lease contracts. This was consistent with the first writ of execution issued by the RTC on December 18, 2003, which directed the levy on real property if personal property was insufficient. The Court further stated that execution shall be applied for in the court of origin, and in this case, the RTC was the court of origin for the orders it issued in the exercise of its equity jurisdiction. Therefore, the RTC correctly ordered the levy on the respondent's real property. On the issue of mootness: The Supreme Court ruled that an issue on jurisdiction prevents a case from becoming moot and academic. While the redemption of the property and release of funds might render certain aspects moot, the fundamental question of whether the RTC had jurisdiction to issue the levy orders remained a justiciable controversy. The Court reiterated that jurisdiction is vested by law and cannot be conferred or waived by parties. Even if a case has been rendered moot, a jurisdictional issue may still be entertained if it presents a situation capable of repetition yet evading judicial review. Thus, the CA correctly exercised its jurisdiction over the petition despite the subsequent events. On the procedural defect of the Verification and Certification against Forum Shopping: The Supreme Court held that the lack of a notarial seal on the Verification and Certification against Forum Shopping was not fatal to the petition before the CA. The Court explained that a defect in verification does not necessarily render a pleading fatally defective, and the court may order its correction or act on the pleading if the ends of justice would be served. While noncompliance with the certification against forum shopping is generally not curable, it is not jurisdictional. In this case, the Verification and Certification were submitted, and all requirements were complied with except for the notarial seal. The Court stressed that courts should not be unduly strict on procedural lapses that do not impair the administration of justice, and litigations should be decided on the merits rather than technicalities. The CA correctly gave due course to the petition as it substantially complied with the requirements.
Main Doctrine
The Regional Trial Court (RTC), as the court of origin, has jurisdiction to order the levy on the respondent's real property in the exercise of its equity jurisdiction, independent of the ejectment case originally filed with the Metropolitan Trial Court (MTC).