G.R. No. 94674 ; March 13, 1991
Spouses Julito Zamora and Lydia Zamora, petitioners, vs. Honorable Court of Appeals (Third Division) and Jose M. Castillo, respondents.

FACTS

Private respondent Jose M. Castillo filed an ejectment complaint against petitioners, the spouses Zamora, before the Metropolitan Trial Court (MTC) of Manila, alleging termination of their lease. In their answer, the Zamoras contested Castillo’s legal capacity to sue, asserting they leased the property from his mother, not from him. The MTC, applying the Rule on Summary Procedure, dismissed the complaint after pre-trial and submission of position papers, ruling Castillo lacked authority because ownership had not yet been formally transferred to him.
On appeal, the Regional Trial Court (RTC) reversed the MTC, holding that ownership is not a decisive issue in ejectment and that Castillo, as a real party-in-interest based on a Memorandum of Agreement and his mother’s directive to the tenants, had the capacity to sue. However, the RTC’s decision merely reinstated the case without awarding relief. Castillo moved to amend the dispositive portion to include ejectment and monetary awards. The RTC denied this, ordering instead that the case be remanded to the MTC for a hearing on the merits, as the MTC had dismissed it purely on a preliminary legal question without trying the factual issues.

ISSUE

Whether the Court of Appeals correctly held that a remand to the MTC for a hearing on the merits was unnecessary under the Rule on Summary Procedure.

RULING

The Supreme Court reversed the Court of Appeals and ordered the remand of the case to the MTC for further proceedings. The legal logic is anchored on the proper application of the Rule on Summary Procedure and appellate procedure. The MTC’s dismissal was based solely on the preliminary question of the plaintiff’s authority to sue, not on a resolution of the factual merits of the ejectment claim, such as the legality of the lease termination. Under Section 8 of the Rule on Summary Procedure, a court may render judgment without a formal hearing only if it can do so based on the pleadings, affidavits, and evidence submitted. Here, the MTC did not reach that stage for the substantive issues because it terminated the case on a jurisdictional/legal threshold.
Consequently, when the RTC correctly reversed the MTC on the capacity issue, the case had to be returned for a determination on the merits. This is mandated by Rule 40, Section 10 of the Rules of Court, which provides that if an inferior court disposes of an action on a question of law without a valid trial on the merits, the appellate court (RTC) upon reversal shall remand the case for further proceedings. The Court of Appeals erred in bypassing this remand, as the factual issues regarding the ejectment remained unresolved and required adjudication by the MTC, the court of origin with jurisdiction over such matters.