Pasig Printing v. Rockland (G.R. No. 193592; February 5, 2014)
CASE DIGEST: PASIG PRINTING CORPORATION v. ROCKLAND CONSTRUCTION COMPANY, INC.
FACTS: MPLDC leased Payanig property or Home Depot property to ECRM Enterprises (ECRM). Subsequently, ECRM assigned all its rights in the contract of lease including the option to renew to Rockland. Later, Rockland erected a building on the area and subleased certain portions to MC Home Depot. In December of 2000, MPLDC demanded that Rockland vacate the property.
To pre-empt any action by MPLDC, Rockland filed the first of the three cases a civil case for specific performance asking MPLDC to execute a 3-year extended contract of lease in its favor.
To protect its interest, MPLDC filed the second case, an unlawful detainer case, before the (MeTC) of Pasig City.
Before the Court could rule on the merits of the petition with regard to the specific performance case, the separate unlawful detainer case was dismissed by the MeTC reasoning out that the issue sought to be resolved was not one of possession, but an exercise of the option to renew a contract cognizable by the RTC.
The Court granted MPLDCs petition, stating, among others, that the issues in the specific performance case should be addressed in the unlawful detainer proceedings before the MeTC, thus, the specific performance case was dismissed.
The unlawful detainer case was elevated to the Court as G.R No. 162924, entitled Mid-Pasig Land Development Corporation v. Mario Tablante (Tablante).
In Tablante, the Court declared that a remand to the MeTC for the unlawful detainer case would have been proper if not for the circumstances which rendered the issue of possession moot and academic. Hence, the Court declared the case as closed and terminated.
Despite its mootness as held in Tablante, the issue of possession again surfaced in the third case, an indirect contempt case pending before the RTC. This was filed against MPLDC for its refusal to reconnect the electric supply in the subject property. But this case was dismissed. The RTC, however, awarded the possession to MPLDC with Rockland being ordered to refrain from exercising any possessory rights over the same.
PPC moved to intervene claiming interest over the property based on an alleged option to lease granted to it by MPLDC.
The RTC issued the Omnibus Order denying Rocklands motion for reconsideration on the dismissal of the indirect contempt case, granting PPCs motion to intervene, and ordering the possession to MPLDC.
On appeal, the CA affirmed, in its Decision, the dismissal of the indirect contempt case, but annulled the award of possession to MPLDC.
The CA ruled reinstating the possession of the property to Rockland.A motion for reconsideration was filed by the movants but denied by the CA. Petitions for certiorari under Rule 45 were also filed before this Court, but the Court dismissed the same reiterating its pronouncement in Tablante that the issue of possession and other related issues had become moot and academic.
Hence, this motion for reconsideration
ISSUE: Did the CA err in ordering the restoration of the possession to Rockland?
HELD: After a thorough review of the records, the Court agrees with the movants in their submission that the dismissal of the petitions would affirm an erroneous ruling which effectively restored the possession of the subject property to Rockland despite the expiration of its contract of lease.
It is a rule of universal application, almost, that courts of justice constituted to pass upon substantial rights will not consider questions in which no actual interests are involved; they decline jurisdiction of moot cases. And where the issue has become moot and academic, there is no justiciable controversy, so that a declaration thereon would be of no practical use or value. There is no actual substantial relief to which petitioners would be entitled and which would be negated by the dismissal of the petition. PLDT v. Eastern Telecomunications Phils, G.R. No. 163037, February 6, 2013
At the time the CA issued its assailed decision, the Court had already pronounced in Tablante the end of Rockland's claim over the subject property because of the expiration of its lease. By that very fact, Rockland has no more possessory right over it.
Granting that the CA was not aware of Tablante, nonetheless, it had no factual or legal basis in ordering the restoration of the possession of the subject property to Rockland. It was very clear in the records that the original lease contract entered into by and between MPLDC and ECRM, the predecessor in interest of Rockland, had long expired in 2003.
While the main case has been declared closed and terminated for being moot and academic, the Court can decide the case on the merits in view of the peculiar circumstances. David v. Macapagal-Arroyo, 522 Phil. 806 (2004)
FACTS: MPLDC leased Payanig property or Home Depot property to ECRM Enterprises (ECRM). Subsequently, ECRM assigned all its rights in the contract of lease including the option to renew to Rockland. Later, Rockland erected a building on the area and subleased certain portions to MC Home Depot. In December of 2000, MPLDC demanded that Rockland vacate the property.
To pre-empt any action by MPLDC, Rockland filed the first of the three cases a civil case for specific performance asking MPLDC to execute a 3-year extended contract of lease in its favor.
To protect its interest, MPLDC filed the second case, an unlawful detainer case, before the (MeTC) of Pasig City.
Before the Court could rule on the merits of the petition with regard to the specific performance case, the separate unlawful detainer case was dismissed by the MeTC reasoning out that the issue sought to be resolved was not one of possession, but an exercise of the option to renew a contract cognizable by the RTC.
The Court granted MPLDCs petition, stating, among others, that the issues in the specific performance case should be addressed in the unlawful detainer proceedings before the MeTC, thus, the specific performance case was dismissed.
The unlawful detainer case was elevated to the Court as G.R No. 162924, entitled Mid-Pasig Land Development Corporation v. Mario Tablante (Tablante).
In Tablante, the Court declared that a remand to the MeTC for the unlawful detainer case would have been proper if not for the circumstances which rendered the issue of possession moot and academic. Hence, the Court declared the case as closed and terminated.
Despite its mootness as held in Tablante, the issue of possession again surfaced in the third case, an indirect contempt case pending before the RTC. This was filed against MPLDC for its refusal to reconnect the electric supply in the subject property. But this case was dismissed. The RTC, however, awarded the possession to MPLDC with Rockland being ordered to refrain from exercising any possessory rights over the same.
PPC moved to intervene claiming interest over the property based on an alleged option to lease granted to it by MPLDC.
The RTC issued the Omnibus Order denying Rocklands motion for reconsideration on the dismissal of the indirect contempt case, granting PPCs motion to intervene, and ordering the possession to MPLDC.
On appeal, the CA affirmed, in its Decision, the dismissal of the indirect contempt case, but annulled the award of possession to MPLDC.
The CA ruled reinstating the possession of the property to Rockland.A motion for reconsideration was filed by the movants but denied by the CA. Petitions for certiorari under Rule 45 were also filed before this Court, but the Court dismissed the same reiterating its pronouncement in Tablante that the issue of possession and other related issues had become moot and academic.
Hence, this motion for reconsideration
ISSUE: Did the CA err in ordering the restoration of the possession to Rockland?
HELD: After a thorough review of the records, the Court agrees with the movants in their submission that the dismissal of the petitions would affirm an erroneous ruling which effectively restored the possession of the subject property to Rockland despite the expiration of its contract of lease.
It is a rule of universal application, almost, that courts of justice constituted to pass upon substantial rights will not consider questions in which no actual interests are involved; they decline jurisdiction of moot cases. And where the issue has become moot and academic, there is no justiciable controversy, so that a declaration thereon would be of no practical use or value. There is no actual substantial relief to which petitioners would be entitled and which would be negated by the dismissal of the petition. PLDT v. Eastern Telecomunications Phils, G.R. No. 163037, February 6, 2013
At the time the CA issued its assailed decision, the Court had already pronounced in Tablante the end of Rockland's claim over the subject property because of the expiration of its lease. By that very fact, Rockland has no more possessory right over it.
Granting that the CA was not aware of Tablante, nonetheless, it had no factual or legal basis in ordering the restoration of the possession of the subject property to Rockland. It was very clear in the records that the original lease contract entered into by and between MPLDC and ECRM, the predecessor in interest of Rockland, had long expired in 2003.
While the main case has been declared closed and terminated for being moot and academic, the Court can decide the case on the merits in view of the peculiar circumstances. David v. Macapagal-Arroyo, 522 Phil. 806 (2004)
