G.R. No. 110223. April 8, 1997.
ARMY AND NAVY CLUB OF MANILA, INC., petitioner, vs. HONORABLE COURT OF APPEALS, HON. WILFREDO D. REYES, as Judge REGIONAL TRIAL COURT OF MANILA, BRANCH 36, HON. A. CAESAR SANGCO, as Judge, METROPOLITAN TRIAL COURT, BRANCH 17-MANILA and the CITY OF MANILA, represented herein by MAYOR ALFREDO LIM, respondents.

FACTS

The City of Manila filed an ejectment complaint against the Army and Navy Club (ANC) in the Metropolitan Trial Court (MTC). The City alleged that ANC violated a 1983 Contract of Lease by failing to construct a modern multi-storied hotel as stipulated, defaulting on rental payments, and failing to pay realty taxes. The City rescinded the contract and demanded that ANC vacate the prime Luneta property. ANC filed its Answer, and later sought to file an Amended Answer to assert new defenses.
The MTC denied ANC’s motion to admit the amended answer. The City then moved for summary judgment, arguing no genuine factual issues existed. The MTC granted the motion, ordering ANC to vacate and pay rental arrears. The Regional Trial Court (RTC) and the Court of Appeals (CA) affirmed the MTC’s summary judgment. ANC elevated the case to the Supreme Court, arguing, among other points, that the MTC improperly denied its motion to amend its answer and that the property, being a historical site, could not be the subject of an ejectment suit.

ISSUE

Whether the Metropolitan Trial Court correctly granted summary judgment in favor of the City of Manila.

RULING

Yes, the MTC correctly granted summary judgment. Summary judgment is proper when, based on the pleadings, affidavits, and admissions, no genuine issue as to any material fact exists, leaving the case to be decided purely on questions of law. Here, the core facts establishing ANC’s breach were not disputed. The existence of the lease contract and ANC’s specific obligations to construct a hotel, pay rent, and pay taxes were admitted. ANC’s failure to perform these core obligations was also not genuinely disputed. Its defenses, including the alleged historical designation of the property, were deemed irrelevant to the simple issue of ejectment based on breach of contract and expiration of the lease term.
The Supreme Court held that the MTC did not err in denying the motion to amend the answer. Amendments are discretionary, and the proposed amendment, which sought to introduce the historical site defense, was correctly seen as a dilatory tactic that would not change the fundamental issue of ANC’s contractual breaches. The designation of a property as a historical site does not immunize a lessee from ejectment for violating lease covenants; it merely imposes certain restrictions on alterations, not on the lessor’s right to recover possession. Since ANC’s breaches were clear and uncontested, the lower courts correctly applied summary judgment to expedite the resolution of the unlawful detainer case.