G.R. No. L-48969 February 29, 1988
BELEN L. VDA. DE GUIA and MELBA O. VALENZUELA, petitioners, vs. HON. ROSARIO R. VELOSO, Judge, City Court of Manila, Branch III, HON. PEDRO A. RAMIREZ, Judge, Court of First Instance of Manila, Branch XXX, THE SHERIFF of the City of Manila, and REPUBLIC MINES & INVESTMENT Co., INC., respondents.

FACTS

This case originated from an ejectment suit filed by respondent Republic Mines and Investment Co., Inc. against petitioners. The disputed property was originally mortgaged by petitioners to the respondent company. Due to petitioners’ failure to pay and redeem, the mortgage was foreclosed, title was consolidated in the company’s name, and a writ of possession was sought. Petitioners filed separate actions for rescission of the mortgage and declaration of premature foreclosure, which were dismissed by the trial court and later affirmed by the Court of Appeals. Meanwhile, the ejectment case proceeded. The City Court ruled for the company, ordering petitioners to vacate and pay P600 monthly as reasonable compensation for use. Only the company appealed this decision to the Court of First Instance (CFI), specifically contesting the rental amount.
The CFI affirmed the ejectment but increased the monthly rental from P600 to P3,000, based on evidence of the property’s commercial value and offers from corporations like Filoil and Mercury Drug. Petitioners then filed this certiorari petition before the Supreme Court, alleging the CFI committed grave abuse of discretion by increasing the rental without due process, as they claimed not to have received pleadings during the appeal. They also argued the CFI failed to consider their other pending cases against the company.

ISSUE

Whether the respondent Court of First Instance committed grave abuse of discretion in increasing the monthly rental award in the ejectment case.

RULING

The Supreme Court dismissed the petition, ruling no grave abuse of discretion was committed. On the due process allegation, the Court found records clearly showed petitioners’ counsel received the necessary pleadings, including the Notice of Appeal, the CFI order allowing memoranda, and the company’s Memorandum. Thus, petitioners were afforded opportunity to be heard, negating any denial of due process.
Regarding the claim that the CFI ignored other pending cases, the Court noted the opposite was true; the CFI took judicial notice of those cases. The rental increase was justified by substantial evidence of the property’s commercial lease value, including petitioner Belen Guia’s own testimony before a Court of Appeals commissioner about lease offers. The Court emphasized that a writ of certiorari corrects only errors of jurisdiction or grave abuse of discretion, not errors of judgment. No such abuse existed as the CFI acted within its jurisdiction and based its rental determination on evidence. Furthermore, with the foreclosure finalized and title consolidated, the company was entitled to possession. The temporary restraining order was dissolved and the CFI decision affirmed.