SECOND DIVISION
[G.R. No. 182074. October 14, 2015.]
SPOUSES DANILO AND PRISCILLA SANCHEZ, petitioner, vs. SPOUSES GERARDO AND EDITHA MANANSALA, respondent.
NOTICE
Sirs/Mesdames :
Please take notice that the Court, Second Division, issued a Resolution dated14 October 2015which reads as follows:
"G.R. No. 182074 (SPOUSES DANILO AND PRISCILLA SANCHEZ v. SPOUSES GERARDO AND EDITHA MANANSALA). — We resolve this petition for review on certiorari challenging the January 17, 2008 decision and March 11, 2008 resolution of the Court of Appeals (CA) in CA-G.R. SP No. 97169. 1 The challenged CA rulings affirmed the Regional Trial Court's (RTC) and Municipal Trial Court's (MTC) decisions 2 to eject petitioners from the property they were then occupying.
THE ANTECEDENTS
Spouses Danilo and Priscilla Sanchez (petitioners) owned a house and lot (property) located at No. 43 Hazleton Street, Vista Verde Country Homes, Cainta, Rizal, and described in TCT No. N1130152. It was mortgaged to the Social Security System.
On September 29, 1999, the petitioners sold their interests and rights over the property to Spouses Gerardo and Editha Manansala (respondents) through a Deed of Transfer with Assumption of Mortgage and Special Power of Attorney (Deed of Transfer). At the petitioners' request, the respondents allowed them to stay for one year. On September 28, 2000, the petitioners requested to extend their stay for another year.
After September 28, 2001, the respondents repeatedly asked the petitioners to vacate the property but the latter refused to heed the demands. On January 22, 2002, the respondents sent them a demand letter to vacate and to turn over the property on or before February 15, 2002; otherwise, they would be compelled to eject the petitioners. The respondents sent another demand letter dated February 15, 2002, giving the petitioners another ten days to vacate the property. Still, the petitioners failed to comply.
On July 4, 2002, the respondents filed an ejectment complaint against the petitioners before the MTC of Cainta, Rizal, but the latter failed to file an answer. When the respondents filed a "Motion for Default and/or to Render Decision," the MTC granted it and rendered judgment in their favor.
On appeal, the RTC affirmed the MTC's decision in toto.
The petitioners filed a petition for review before the CA seeking to reverse the RTC's decision. The petitioners argued that this case involves the enforcement of their Deed of Transfer and does not merely involve an ejectment. Thus, the MTC does not have jurisdiction.
They also argued that the RTC erred in affirming the MTC's decision because they were not furnished with the September 13, 2012 Order which granted the motion to render judgment.
The CA dismissed the petition and affirmed the RTC's decision in toto; hence, this petition.
The issues before this Court are first, whether the complaint is for ejectment and second, whether the MTC's decision is valid even though the petitioners were not furnished with a copy of the MTC order granting the motion to render judgment.
THE COURT'S RULING
We DENY the petition.
The complaint is one for
The allegations in the complaint and the character of relief sought determine the nature of the action and the court's jurisdiction. 3 A complaint sufficiently alleges a cause of action for unlawful detainer if it recites the jurisdictional elements. 4
As correctly ruled by the CA, a review of the complaint shows that all the elements are present: (1) the respondents allowed the petitioners to stay in the property for a year after the latter sold their rights to it; (2) the respondents sent three demand letters forcing the petitioners to vacate the property; (3) despite these demands, the petitioners refused to vacate the property; and (4) the respondents filed the complaint five months after the last demand. Thus, the complaint sufficiently alleged an action for unlawful detainer; hence, the MTC correctly exercised jurisdiction over this case.
Non-receipt of the order to
An unlawful detainer action is governed by the Rule on Summary Procedure. 5 If the defendant fails to timely submit an answer, section 6 6 of the Rule allows the court to render judgment, either upon motion or motuproprio.
In the present case, the petitioners failed to file an answer and offered no explanation to justify its inaction; thus, the MTC rendered judgment on the case. That the petitioners did not receive the order granting the motion to render judgment, is not legally significant as the MTC, on its own or upon motion, can render judgement pursuant to the above-cited Rule. Thus, its judgment should stand.
The petitioners erroneously insisted that they were absolutely denied the reasonable opportunity to be heard and to submit evidence to support their defense. This position is not meritorious. The petitioners were given a period of ten days to file their answer but they did not. When they received the MTC's decision, they belatedly argued that they did not receive the MTC order granting the motion to render judgment.
We emphasize that actions for unlawful detainer are summary in nature. They disturb the social order, hence, the rule on these actions must be promptly abated without undue reliance on procedural rules in order to avoid delays. 7
Since the MTC ruling finds support in law, the CA did not commit any reversible error in upholding the petitioner's ejectment from the property.
WHEREFORE, we hereby DENY the petition for lack of merit. The January 17, 2008 decision and March 11, 2008 resolution of the Court of Appeals in CA-G.R. SP No. 97169 are hereby AFFIRMED. Costs against petitioners.
SOORDERED."
Very truly yours,
MA. LOURDES C. PERFECTODivision Clerk of Court
By:
(SGD.) TERESITA AQUINO TUAZONDeputy Division Clerk of Court
Footnotes
* Carpio, J., on official leave; Brion, J., designated as acting Chairperson, per Special Order No. 2222 dated September 29, 2015; Peralta, J., designated as acting Member in lieu of Associate Justice Antonio T. Carpio, per Special Order No. 2223 dated September 29, 2015.
1.Rollo, pp. 28-42. Penned by Associate Justice Vicente S.E. Veloso and concurred in by Associate Justices Juan Q. Enriquez, Jr. and Marlene Gonzales-Sison.
2.Id. at 98-99, 81-85.
3.Optimum Development Bank v. Spouses Jovellanos, G.R. No. 189145, December 4, 2013, 711 SCRA 548, 555.
4.Macaslang v. Zamora, G.R. No. 156375, May 30, 2011, 649 SCRA 92, 104:
(a) Initially, the possession of the property by the defendant was by contract with or by tolerance of the plaintiff;
(b) Eventually, such possession became illegal upon notice by the plaintiff to the defendant about the termination of the latter's right of possession;
(c) Thereafter, the defendant remained in possession of the property and deprived the plaintiff of its enjoyment; and
(d) Within one year from the making of the last demand to vacate the property on the defendant, the plaintiff instituted the complaint for ejectment.
5. Sec. 1 (A) (1), Rule on Summary Procedure.
6. Sec. 6. Effect of failure to appear. — Should the defendant fail to answer the complaint within the period above provided, the court, motu proprio or on motion of the plaintiff, shall render judgment as may be warranted by the facts alleged and limited to what is prayed for therein.
7. Id.