GR 130907; (November, 2001) (Digest)
G.R. No. 130907; November 27, 2001
Republic of the Philippines (represented by the Philippine Human Resources Development Center and Construction Manpower Development Foundation), petitioner, vs. Hon. Cesar A. Mangrobang, Presiding Judge of RTC-Cavite, Branch 22, Imus, Philippine Women’s University and Helena Z. Benitez, respondents.
FACTS
The Republic, through its agencies PHRDC and CMDF, entered into a lease agreement with respondent Helena Z. Benitez over a property in Cavite. After the initial lease term, negotiations for the sale of a portion of the property ensued, leading to a dispute over unpaid rentals. Benitez and PWU filed an ejectment case before the Municipal Trial Court (MTC), which ruled in their favor. The Republic appealed this decision to the Regional Trial Court (RTC), where it was docketed as Civil Case No. 055-96 and assigned to Branch 22, presided by respondent Judge Mangrobang.
Simultaneously, the Republic instituted an original action for Eminent Domain over the same property before another branch of the same RTC, Branch 20, docketed as Civil Case No. 1277-96. Respondents then filed a Petition for Consolidation of the appealed ejectment case (055-96) with the eminent domain case (1277-96). Judge Mangrobang granted the consolidation, ordering the ejectment case to be jointly tried with the eminent domain case in Branch 20. The Republic’s motion for reconsideration was denied.
ISSUE
Whether the respondent judge committed grave abuse of discretion in ordering the consolidation of an appealed ejectment case with an original eminent domain case.
RULING
Yes, the Supreme Court granted the petition and set aside the consolidation orders. The legal basis for consolidation under Section 1, Rule 31 of the Rules of Civil Procedure requires common questions of law or fact. The Court found that while the cases involved the same property, they presented dissimilar causes of action and issues. The ejectment case concerned the issue of possession de facto, while the eminent domain case involved the State’s exercise of its inherent power to take private property for public use upon payment of just compensation.
Furthermore, the Court emphasized the different jurisdictions exercised by the RTC in each case: appellate jurisdiction over the appealed ejectment decision and original, exclusive jurisdiction over the eminent domain proceeding. Consolidation was deemed inappropriate as a decision in one case would not necessarily resolve the other, and it would cause undue procedural complication and delay, especially since the eminent domain case was already urgent and partially heard. The respondent judge’s order, under these circumstances, constituted a grave abuse of discretion. The cases were ordered to proceed independently.