G.R. No. 152131 . April 29, 2009.
FLORAIDA TERAÑA, Petitioner, vs. HON. ANTONIO DE SAGUN, PRESIDING JUDGE, REGIONAL TRIAL COURT, BRANCH XIV, NASUGBU, BATANGAS AND ANTONIO B. SIMUANGCO, Respondents.

FACTS

Respondent Antonio Simuangco owned a house and lot in Nasugbu, Batangas, which he leased to petitioner Floraida Terana. The Contract of Lease required the lessee to keep the property in its original condition and not to make alterations without the lessor’s consent. In 1996, petitioner demolished the leased house and erected a new one. Respondent alleged this was done without his consent, constituting a violation of the lease contract, and filed a complaint for unlawful detainer. Petitioner claimed she acted with respondent’s knowledge and consent, as the original house was old and on the verge of collapsing. The Municipal Trial Court (MTC), applying the Revised Rules of Summary Procedure, rendered a decision in favor of respondent, ordering petitioner to vacate and pay attorney’s fees, despite both parties’ failure to timely file their position papers due to denied motions for extension. Petitioner filed her position paper and affidavits late, after the MTC decision was rendered. On appeal, the Regional Trial Court (RTC) initially affirmed the MTC decision but later granted petitioner’s motion for reconsideration, setting aside both decisions and remanding the case to the MTC for further proceedings to allow the filing of position papers. Petitioner moved for reconsideration of the remand order, arguing the RTC should have conducted a trial de novo. The RTC denied this motion. The Court of Appeals affirmed the RTC’s orders for remand.

ISSUE

Whether the Regional Trial Court acted correctly in remanding the unlawful detainer case to the Municipal Trial Court for further proceedings after granting a motion for new trial, instead of conducting a trial de novo itself.

RULING

No. The Supreme Court ruled that the RTC erred in remanding the case to the MTC. Under the Revised Rules of Summary Procedure, which governs unlawful detainer cases at the MTC level, the rule prohibiting motions for extension of time to file pleadings is mandatory. The MTC correctly rendered judgment based on the pleadings and evidence on record when the parties failed to file their position papers. The RTC, on appeal, has the authority to review errors of law or fact and has the power to receive evidence or conduct a trial de novo if necessary in the interest of justice. However, a remand to the MTC is not the proper procedure after granting a motion for new trial on appeal. The RTC should have conducted the trial de novo itself, as it is vested with original jurisdiction over cases falling within its exclusive original jurisdiction and appellate jurisdiction over cases decided by lower courts. The Court of Appeals’ decision was reversed and set aside. The case was remanded to the RTC, which was directed to conduct a trial de novo, receive the parties’ evidence, and render judgment on the merits.