San Pedro v. Trinidad
REITERATIONFacts
The Antecedents: Spouses Angelito and Consuelo Trinidad filed a forcible entry case against Reynaldo San Pedro and others, alleging that Reynaldo, despite having sold his rights to the property to them via a Deed of Absolute Sale with Waiver of Rights, unlawfully entered and possessed the 188.80 square meter property in Valenzuela, Sta. Rosa, Nueva Ecija. Spouses Trinidad claimed they were the rightful owners and possessors, and that Reynaldo's entry was forceful and stealthy. Reynaldo, in defense, asserted continuous possession of the property since time immemorial and questioned the specifics of the alleged dispossession. Procedural History: The Municipal Trial Court (MTC) initially dismissed the forcible entry case, finding that the spouses Trinidad failed to prove prior physical possession. Upon appeal, the Regional Trial Court (RTC) determined it had jurisdiction, treating the case as accion publiciana due to the property's assessed value. The RTC found that Reynaldo had transferred his rights to the spouses Trinidad but failed to surrender physical possession, ordering Reynaldo to vacate and place the spouses Trinidad in possession. Reynaldo's motion for reconsideration was denied. Subsequently, Reynaldo filed a Notice of Appeal with the Court of Appeals (CA). The Petition: The Court of Appeals dismissed Reynaldo's appeal, ruling that a Notice of Appeal was an improper mode of review and that a Petition for Review under Rule 42 was required for appeals from RTC decisions rendered in its appellate capacity. Reynaldo's motion for reconsideration was denied. He then filed a Petition for Review on Certiorari with the Supreme Court, arguing that the RTC's decision was rendered in its original jurisdiction, not appellate. During the pendency of the case, Reynaldo passed away and was substituted by his son, Raymonde San Pedro.
Issue(s)
Whether the Court of Appeals erred in ruling that the appropriate mode of appeal from the Regional Trial Court's decision was a petition for review instead of an ordinary appeal; and whether the RTC erred in ordering Reynaldo to vacate the property.
Ruling
The Petition for Review on Certiorari is DENIED. The Resolutions dated January 11, 2023 and February 7, 2024 of the Court of Appeals in CA-G.R. SP No. 174613 are AFFIRMED.
Ratio Decidendi
On Whether the Court of Appeals erred in ruling that the appropriate mode of appeal from the Regional Trial Court's decision was a petition for review instead of an ordinary appeal; and whether the RTC erred in ordering Reynaldo to vacate the property: The Supreme Court held that the Court of Appeals (CA) did not err in dismissing Reynaldo's appeal for being an improper mode of review. The RTC's decision, which was appealed to the CA, was rendered in the exercise of its appellate jurisdiction, not original jurisdiction. This is in accordance with Rule 40, Section 8 of the Rules of Court, which states that if a Municipal Trial Court (MTC) tried a case on the merits despite lacking jurisdiction, the RTC, on appeal, shall not dismiss the case if it has jurisdiction, but shall try it on the merits as if originally filed. The Court explicitly referenced and applied its ruling in De Vera v. Spouses Santiago, which deemed a decision of the RTC under Rule 40, Section 8 as one promulgated in the exercise of its appellate jurisdiction. The phrase 'as if the same was originally filed before it' in Rule 40, Section 8 does not convert the type of jurisdiction being exercised by the RTC; it merely allows the RTC to proceed with the case on the merits in the interest of convenience and judicial economy, rather than dismissing it for refiling. Therefore, under Rule 41, Section 2(b) of the Rules of Court, the proper mode of appeal to the CA from an RTC decision rendered in its appellate jurisdiction is a petition for review under Rule 42, not an ordinary appeal by notice of appeal. As Reynaldo filed a notice of appeal instead of a petition for review, the CA correctly dismissed his appeal pursuant to Rule 50, Section 2 of the Rules of Court, leading to the finality of the challenged RTC Decision. The Court further noted that the RTC did not err in ordering Reynaldo to vacate the property, as he admitted signing the notarized Deed of Absolute Sale with Waiver of Rights (DOAS) in favor of spouses Trinidad, and failed to substantiate his claim that the transaction was a loan, thus spouses Trinidad, as owners, have a better right to possession.
Main Doctrine
The Supreme Court clarified that when a Regional Trial Court (RTC) decides a case on the merits under Rule 40, Section 8 of the Rules of Court, after an appeal from a Municipal Trial Court (MTC) that lacked jurisdiction but tried the case, the RTC is exercising its appellate jurisdiction. The phrase 'as if the case was originally filed with it' in the rule does not convert the RTC's jurisdiction to original jurisdiction. Consequently, the proper mode of appeal from such an RTC decision to the Court of Appeals (CA) is a petition for review under Rule 42, not an ordinary appeal under Rule 41. This doctrine ensures judicial economy by allowing the RTC to resolve the case on the merits rather than dismissing it for refiling, while maintaining the correct procedural path for subsequent appeals.