GR 129382; (January, 2002) (Digest)
G.R. No. 129382 ; January 23, 2002
VICTOR SIASAT and JESUS ONG, petitioners, vs. COURT OF APPEALS, HON. FELICIDAD Y. NAVARRO-QUIAMBAO, in her capacity as Presiding Judge, MTC, Br. 65, Makati City, JOEL FERAREN, in his capacity as Deputy Sheriff of the aforesaid Court, and GENIE DEVELOPMENT CORPORATION, respondents.
FACTS
Private respondent Genie Development Corporation (GDC) filed an ejectment case against petitioners Victor Siasat and Jesus Ong in the Metropolitan Trial Court (MTC) of Makati. Petitioners were served with summons but failed to file an answer within the reglementary period, leading to their declaration in default. Their counsel’s motion to lift the order of default was denied, and the MTC rendered a decision against them. No appeal was filed, resulting in the issuance of a writ of execution. The ejectment was enforced, and the sheriff levied on petitioners’ personal properties for the monetary award.
Petitioners filed a petition for relief from judgment with the Regional Trial Court (RTC), blaming their former counsel’s negligence for the default and failure to appeal. The RTC initially issued orders granting a preliminary injunction and releasing the levied properties. However, the Court of Appeals, in a certiorari petition filed by GDC, annulled these RTC orders for grave abuse of discretion. GDC then moved for summary judgment in the RTC, which was granted. The Court of Appeals affirmed this summary judgment.
ISSUE
Whether there exist genuine issues of material facts that would preclude the rendition of a summary judgment on the petition for relief from judgment.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal logic is twofold. First, the petition for relief from judgment filed by petitioners in the RTC was a prohibited pleading. The case originated from an ejectment action, which is governed by the Revised Rule on Summary Procedure. Under Section 19 of this Rule, a petition for relief from judgment is expressly prohibited. Therefore, the RTC should not have entertained it at all.
Second, the Court upheld the factual findings of the Court of Appeals, noting that in an appeal via certiorari, factual conclusions of the appellate court are generally binding and conclusive unless they fall under specific exceptions, none of which were present here. The Court found no genuine issue of material fact that would necessitate a trial. The procedural history was clear and established: petitioners were declared in default, failed to appeal the MTC decision, and their attempt to seek relief via a prohibited pleading was invalid. Thus, the grant of summary judgment by the RTC, as affirmed by the Court of Appeals, was legally sound.