G.R. No. L-48975 August 30, 1982
RAFAEL B. MAGPANTAY, petitioner, vs. THE HONORABLE COURT OF APPEALS, RUFINO B. ALCASID CORPORATION, BALDOMERO E. MALABRIGO, and THE HONORABLE SEVERO A. MALVAR, Presiding Judge of the CFI of Laguna, Branch VI, respondents.
FACTS
Rufino Alcasid Corporation filed an ejectment complaint against its lessee, Baldomero Malabrigo, for non-payment of rent. Malabrigo, in turn, filed a third-party complaint against Rafael Magpantay, to whom he had sublet a portion of the property. The corporation and Malabrigo subsequently entered into a compromise agreement, which the Municipal Court approved. The court, based on this agreement and the evidence, ordered Magpantay to pay Malabrigo back rentals and vacate the premises. Magpantay appealed to the Court of First Instance, which affirmed the decision.
Magpantay then elevated the case to the Court of Appeals via a petition for review. He argued that the compromise agreement between the corporation and Malabrigo was not binding on him as a non-party and that his resulting ouster violated Presidential Decree No. 20, which suspended ejectment under Article 1673(1) of the Civil Code for dwelling units. He contended this created a scheme to bypass the decree’s protections for actual occupants.
ISSUE
Whether the Supreme Court can review the factual findings of the lower courts regarding Magpantay’s default in rental payments and the application of PD No. 20 to his case.
RULING
The Supreme Court dismissed the petition. The legal logic is anchored on the principle that factual findings of the Court of Appeals are binding and conclusive upon the Supreme Court, absent any showing of grave abuse of discretion or misapprehension of facts. The Municipal Court, Court of First Instance, and Court of Appeals were unanimous in their factual conclusion that Magpantay had defaulted in the payment of his rentals to sublessor Malabrigo. This finding of default was crucial, as it rendered his invocation of PD No. 20 unavailing. The protective mantle of PD No. 20, which suspends certain grounds for ejectment, does not extend to a lessee or sublessee who has failed to pay rent. Consequently, Magpantay, as a defaulting sublessee, could not claim rights better than those of his immediate sublessor, Malabrigo, who was also in default. The Supreme Court emphasized that the petition raised essentially factual issues, which are not proper subjects for a review by certiorari, as only questions of law may be entertained in such proceedings.
