GR L 38467; (June, 1974) (Digest)
G.R. No. L-38467 June 28, 1974
CATALINA BARDELAS, ET AL., petitioners-appellants, vs. HON. ANTONIO E. RODRIGUEZ, as Municipal Judge, Las Piñas, Rizal and Spouses PAZ BASA ANDRES, respondents-defendants-appellees.
FACTS
Private respondent Paz Basa Andres filed an ejectment case against petitioners, who were her tenants, in the Municipal Court of Las Piñas for their failure to pay rentals. The petitioners moved to dismiss the complaint on several grounds, including the alleged applicability of Republic Act No. 267 (as amended) and Republic Act No. 6126, which they argued suspended ejectment proceedings. They also challenged the plaintiff’s legal capacity to sue. The municipal court denied the motions to dismiss. The petitioners then filed a petition for certiorari, mandamus, and prohibition with the Court of First Instance of Rizal, seeking to restrain the ejectment case. The CFI dismissed their petition. Petitioners appealed to the Court of Appeals, which certified the case to the Supreme Court as it raised purely legal questions.
ISSUE
Whether the Court of First Instance of Rizal committed grave abuse of discretion in dismissing the petitioners’ special civil action (certiorari, mandamus, and prohibition) which sought to challenge the municipal court’s denial of their motion to dismiss in the ejectment case.
RULING
The Supreme Court ruled that the CFI did not commit grave abuse of discretion and affirmed the dismissal of the petition. The Court clarified that the ejectment action was properly based on the lessor’s prior physical possession and the tenants’ failure to pay the agreed rentals, a valid ground for ejectment under Article 1673(2) of the Civil Code. The legal provisions invoked by the petitioners were inapplicable. Republic Act No. 6126, which suspends ejectment for expiration of lease terms, does not apply where the cause is non-payment of rent. Furthermore, Republic Act No. 267, regarding expropriation for socialized housing, was not controlling as the Municipality of Las Piñas had not actually instituted expropriation proceedings for the subject land. The Court also found that Paz Basa Andres had the legal capacity to sue, as the property was adjudicated as her separate property. The CFI correctly found the petition lacked cause of action, as the municipal court’s orders were not issued with grave abuse of discretion. The appeal was dismissed for lack of merit.