GR 121646; (June, 1999) (Digest)
G.R. No. 121646 June 21, 1999
Spouses Dr. Claro L. Montecer and Carina P. Montecer, petitioners, vs. Court of Appeals and Spouses Petronilo Bautista and Iluminada L. Bautista, respondents.
FACTS
Petitioners, the registered owners of a parcel of land, filed an unlawful detainer case against private respondents before the Municipal Circuit Trial Court (MCTC). Petitioners alleged that they discovered in 1987 that respondents had occupied a portion of their land and built a house thereon. Despite demands, respondents refused to vacate. The MCTC ruled in favor of petitioners, ordering respondents to vacate and pay monthly rent. On appeal, the Regional Trial Court (RTC) affirmed the MCTC’s decision on possession but identified unresolved factual issues regarding the specific portions and value of the house built in 1961 versus 1991. The RTC, stating it could not resolve these factual matters on appeal, remanded the case to the MCTC for further reception of evidence. The Court of Appeals affirmed the RTC’s order of remand.
ISSUE
Whether the Regional Trial Court, in the exercise of its appellate jurisdiction over an ejectment case, is mandated by Section 21(d) of the Interim Rules to decide the case based solely on the record from the court of origin, even if that record is allegedly insufficient to resolve certain factual issues.
RULING
The Supreme Court granted the petition, reversing the decisions of the CA and RTC and reinstating the MCTC judgment. The Court clarified that while Section 21(d) of the Interim Rules generally directs the RTC to decide the case on the basis of the entire record from the lower court, this rule is not inflexible. The RTC retains the authority to receive additional evidence or remand the case when indispensable matters were not passed upon by the trial court, provided such action is necessary for a complete resolution of the dispute. However, in this specific instance, a remand was unjustified. The respondents, who raised the issue of their house’s value in their answer, failed to present any supporting evidence during the MCTC trial. This failure constituted a waiver of their right to present such evidence on appeal. To remand the case to allow them to belatedly present evidence would unjustly burden the petitioners and unduly delay the proceedings, especially since the core issue of rightful possession had already been conclusively resolved in the petitioners’ favor by the trial court.