G.R. No. L-68789 November 10, 1986
JOSE LEE and FELIX LIM, petitioners, vs. HON. PRESIDING JUDGE, MUNICIPAL TRIAL COURT OF LEGAZPI CITY, BRANCH I, HON. INTERMEDIATE APPELLATE COURT, and SPOUSES ROY PO LAM and JOSEFA PO LAM, respondents.

FACTS

Private respondents, the Spouses Po Lam, filed an ejectment case (Civil Case No. 2687) against petitioner Jose Lee before the Municipal Trial Court (MTC) of Legazpi City. They alleged an expired oral lease and sought Lee’s eviction from a commercial property they claimed to own. Petitioner Lee, in his answer, denied the spouses’ ownership, citing a final Court of Appeals decision (CA-G.R. No. 44770) which declared petitioner Felix Lim as the owner of a portion of the property and a redemptioner of the rest. Felix Lim subsequently intervened in the ejectment case, asserting his rights as the declared owner and redemptioner. Meanwhile, Lim had also filed separate actions (Civil Cases No. 6696 and 6767) before the then Court of First Instance (CFI) of Albay, questioning the Po Lams’ title and seeking reconveyance of the same property.

ISSUE

The primary issue is whether the Intermediate Appellate Court (IAC) acted with grave abuse of discretion in dismissing the appeal from the MTC decision instead of certifying it to the proper appellate court.

RULING

The Supreme Court granted the petition. It held that the IAC committed a reversible error in dismissing the appeal. The legal logic centers on the proper appellate jurisdiction following the enactment of Batas Pambansa Blg. 129 (the Judiciary Reorganization Act of 1980). While the case originated in a city court (later an MTC), and under the old law (R.A. 5967) its decisions were directly appealable to the Court of Appeals, this procedure was superseded by B.P. 129. Section 22 of B.P. 129 explicitly grants Regional Trial Courts (RTCs) appellate jurisdiction over all cases decided by MTCs. Since B.P. 129 was already in effect when the petitioners appealed the MTC’s 1983 decision, the appeal should have been filed with the RTC, not the IAC.
Consequently, under Rule 50, Section 3 of the Revised Rules of Court, the IAC’s duty upon finding an erroneously filed appeal was not to dismiss it, but to certify the case to the proper court—the Regional Trial Court of Albay. The IAC’s failure to do so constituted a grave abuse of discretion. The Supreme Court thus set aside the IAC’s resolutions and ordered the remand of the MTC’s decision to the RTC of Albay for appropriate appellate proceedings. The Court did not rule on the substantive merits of the ownership or ejectment claims, leaving those for the proper court’s determination on appeal.