GR 73471; (May, 1990) (Digest)
G.R. No. 73471 May 8, 1990
RUFINA ORATA, petitioner, vs. HON. INTERMEDIATE APPELLATE COURT, HON. OTILIO G. ABAYA, Presiding Judge, Regional Trial Court of Pasig, M.M., Branch CLIV (154), and GERTRUDES REYES, as Judicial Administratrix of the Estate of the Late Florencio dela Cruz, respondents.
FACTS
Gertrudes Reyes, as judicial administratrix of her late husband Florencio dela Cruz’s estate, filed an ejectment case against Rufina Orata for non-payment of rentals on a leased lot. Orata defended that she had been paying rentals to Celso Teodoro, the registered owner of the property per the Certificate of Title, who she believed was the rightful lessor as the grandson of the deceased. The Metropolitan Trial Court ruled for Reyes, ordering Orata’s ejectment, and the Regional Trial Court affirmed this decision.
Orata filed a petition for review with the Intermediate Appellate Court (IAC), which dismissed it for being filed beyond the 15-day reglementary period. The IAC counted the period from Orata’s receipt of the RTC decision, ruling that her subsequent motion for reconsideration did not toll the period, as such a motion is not a prerequisite for a petition for review. Orata then elevated the case to the Supreme Court via certiorari.
ISSUE
Whether the IAC gravely abused its discretion in dismissing the petition for review on purely technical grounds, thereby disregarding the merits of the case which involve strong considerations of substantial justice.
RULING
The Supreme Court granted the petition, annulling the IAC’s resolution. While the Court acknowledged that the petition for review was technically filed late, it emphasized that rules of procedure are tools to facilitate justice, not to hinder it. The Court exercised its equity jurisdiction to relax the stringent application of technical rules because the case presented a compelling substantive merit that warranted a hearing on the facts.
The legal logic is clear: Orata’s defense was valid. At the time of the demand and filing of the ejectment complaint, Celso Teodoro was the registered owner per the Torrens title. Payment made in good faith to the person in possession of the credit (the registered owner-lessor) releases the debtor under Article 1242 of the Civil Code. Since Orata was not in default, having paid the registered owner, the administratrix had no cause of action for ejectment. The subsequent cancellation of Teodoro’s title in 1983 did not retroactively make Orata’s prior payments invalid. Thus, dismissing the appeal on a technicality would perpetrate a grave injustice when the substantive defense was legally sound. The complaint for ejectment was ordered dismissed.