GR 156142; (March, 2011) (Digest)
G.R. No. 156142; March 23, 2011
SPOUSES ALVIN GUERRERO AND MERCURY M. GUERRERO, Petitioners, vs. HON. LORNA NAVARRO DOMINGO, IN HER CAPACITY AS PRESIDING JUDGE, BRANCH 201, REGIONAL TRIAL COURT, LAS PIÑAS CITY & PILAR DEVELOPMENT CORPORATION, Respondents.
FACTS
On June 2, 1997, respondent Pilar Development Corporation (PDC) and petitioners Spouses Guerrero entered into a Contract to Sell for a house and lot. On February 5, 2002, PDC filed a Complaint for Unlawful Detainer against the spouses in the Metropolitan Trial Court (MeTC) of Las Piñas City, docketed as Civil Case No. 6293. The complaint alleged that the spouses stopped payments, prompting PDC to cancel the Contract to Sell on November 19, 2001, and that they refused to vacate the property. The spouses Guerrero filed an Answer, arguing the MeTC had no jurisdiction because the action impermissibly joined a cause for extinguishment of contract (beyond pecuniary estimation) with an action for unlawful detainer.
Subsequently, on April 10, 2002, the spouses filed a Petition for Prohibition with the Regional Trial Court (RTC), Branch 201, docketed as Civil Case No. SCA-02-0007, seeking to quash the MeTC complaint on the same jurisdictional ground. The MeTC proceeded and rendered a Decision on September 30, 2002, in favor of PDC, holding it had jurisdiction as the suit was an unlawful detainer case. The spouses appealed this MeTC Decision to the RTC, Branch 197. On November 18, 2002, RTC Branch 201 denied the Petition for Prohibition. Meanwhile, on June 20, 2003, RTC Branch 197 dismissed the spouses’ appeal in the unlawful detainer case for failure to file their memorandum.
ISSUE
Whether the Regional Trial Court correctly denied the Petition for Prohibition filed by the spouses Guerrero seeking to prevent the MeTC from hearing the unlawful detainer case on the ground of alleged lack of jurisdiction due to a joinder of causes of action.
RULING
The Supreme Court DENIED the Petition for Review and AFFIRMED the RTC’s Order denying the Petition for Prohibition.
1. Prohibition is an improper remedy as the act sought to be prevented was already a fait accompli. The writ of prohibition is preventive and seeks to prevent an illegal act. The act sought to be enjoined by the petition—the MeTC’s hearing and disposition of Civil Case No. 6293—had already been accomplished. The MeTC had already decided the case, and the appeal therefrom had been dismissed by the RTC. Therefore, prohibition no longer lay.
2. Petitioners had a plain, speedy, and adequate remedy in the ordinary course of law. A party cannot resort to the extraordinary writ of prohibition under Rule 65 when an appeal or other adequate remedy is available. The spouses Guerrero could have raised the ground of lack of jurisdiction through a Motion to Dismiss or, as they did, as an affirmative defense in their Answer in the unlawful detainer case itself, which is expressly allowed under Section 13, Rule 70 of the Rules of Court. This was a sufficient and adequate legal remedy, making a petition for prohibition unwarranted.
The Court did not find it necessary to rule on the substantive issue of whether the MeTC correctly assumed jurisdiction over the unlawful detainer case, as the petition was dismissed on procedural grounds pertaining to the propriety of the remedy of prohibition.