G.R. No. L-243; April 30, 1947
BASILIO BAUTISTA, GERTRUDES IGNACIO and SIMON IGNACIO, plaintiffs-appellees, vs. ARISTIDES GONZALES, defendant-appellant.

FACTS

On August 27, 1945, the plaintiffs filed an ejectment action against the defendant in the municipal court of Manila. The defendant was ordered to vacate the premises (Nos. 1457-1459 Quezon Boulevard) and to pay monthly rental from July 1, 1945. The defendant appealed to the Court of First Instance of Manila, where he filed an answer primarily challenging the validity of the sale by which the plaintiffs acquired ownership of the property. The plaintiffs moved for a summary judgment, alleging the defendant’s answer did not raise a genuine issue for trial. The defendant filed an opposition. The Court of First Instance rendered a decision in favor of the plaintiffs.

ISSUE

Whether the trial court correctly granted the plaintiffs’ motion for a summary judgment in the ejectment case.

RULING

Yes. The Supreme Court affirmed the appealed decision. The Court held that a summary judgment was proper because no genuine controversy existed warranting a formal trial. The defendant admitted in his opposition and supporting affidavit that he had been paying rent to the plaintiffs from July 1944 to April 1945 and then stopped, pending a government determination on sales paid in Japanese military notes. This admission established the landlord-tenant relationship. The defendant’s admitted default in rent payment was sufficient legal justification for his ejectment. The question of ownership raised by the defendant was deemed non-essential and foreign to the ejectment proceedings, as such an issue could be raised in a separate appropriate action. The ejectment decision did not bind or affect the title or ownership of the property. The defendant’s arguments on ownership were therefore irrelevant to the ejectment case. The summary judgment procedure was authorized under the Rules of Court to promptly dispose of actions lacking a genuine controversy.