GR 163602; (September, 2011) (Digest)
G.R. No. 163602; September 7, 2011
SPOUSES EULOGIA MANILA and RAMON MANILA, Petitioners, vs. SPOUSES EDERLINDA GALLARDO-MANZO and DANIEL MANZO, Respondents.
FACTS
Respondents (Spouses Manzo) filed an ejectment case against petitioners (Spouses Manila) before the Metropolitan Trial Court (MeTC) of Las Piñas City. The action was based on a Contract of Lease dated June 30, 1982, which expired on July 1, 1992. The lessee (petitioner Eulogia Manila) failed to vacate and pay rental arrearages despite demand. Petitioners claimed they had exercised an option to buy the property within the contract’s stipulated period, making them owners and thus no rentals were due. The MeTC ruled in favor of the respondents, ordering petitioners to vacate, pay rental arrearages and compensation, and attorney’s fees. On appeal, the Regional Trial Court (RTC) of Makati reversed the MeTC. The RTC found that petitioners had validly exercised the option to buy. It ordered respondents to execute a deed of absolute sale upon petitioners’ payment of the purchase price. Respondents filed a motion for reconsideration, which the RTC denied for having been filed beyond the reglementary period. The RTC decision became final and executory. Respondents subsequently filed a petition for annulment of the RTC decision with the Court of Appeals (CA).
ISSUE
Whether the Court of Appeals correctly annulled the decision of the Regional Trial Court on the ground of lack of jurisdiction.
RULING
No. The Supreme Court reversed the CA decision and reinstated the RTC decision. The petition for annulment of judgment under Rule 47 is an extraordinary remedy available only when ordinary remedies are no longer available through no fault of the petitioner and only on grounds of extrinsic fraud or lack of jurisdiction. In this case, the loss of the ordinary remedy of appeal was due to respondents’ own fault (their counsel’s late filing of the motion for reconsideration). Furthermore, the RTC did not lack jurisdiction. Jurisdiction is conferred by law and determined by the allegations in the complaint. The complaint was for ejectment, over which the RTC properly exercised its appellate jurisdiction. While the RTC, in deciding the appeal, resolved the issue of ownership incidental to the issue of possession, this was within its authority. The Rules of Court allow the resolution of the issue of ownership if it is necessary to decide the issue of possession definitively. The RTC’s finding that the option to buy was validly exercised and its consequent order for the execution of a sale were within the scope of its power to resolve the ejectment case completely and finally. The CA erred in annulling the RTC decision.