GR No. 197582
June 29, 2015
Facts
Petitioner leased to respondent two units of the apartments he owned. Thereafter, petitioner decided to terminate the lease but the respondent refused to vacate the premises. Hence, petitioner filed an ejectment case which the MTC resolved in its favor. The MTC ordered the respondent to vacate the premises and pay the rentals. Such Order was affirmed by the RTC but the CA dismissed the ejectment case.
Consequently, respondent consigned to the Court the amount of rentals because of petitioner’s refusal to accept such. Thereafter, petitioner filed a motion to withdraw the amount of rentals consigned and was granted. However, the respondent filed a motion for reconsideration opposing the Order granting the motion to withdraw the funds because the dismissal of the ejectment case means that there is no complaint at all. The RTC denied the motion for reconsideration. The CA affirmed the denial and argued that the RTC Orders were pursuant to its equity jurisdiction in accordance with Section 5, Rule 39, 14 and Rules 5 and 6 of Rule 135 of the Rules of Court. Furthermore, the Supreme Court affirmed the ruling of the RTC.
Thereafter, the petitioner moved for the levy of the property of the respondent because of the insufficiency of the amount of lease payments tendered in Court. Such motion was granted by the RTC. However, the CA reversed the decision of the RTC because the RTC has no jurisdiction to levy on respondent’s real property because the approval of the levy on the respondent’s real property could not be considered as a case pending appeal for the decision of the MTC had already become final and executory. Hence, the matter of execution of the judgment lies with the MTC where the complaint for ejectment was originally filed and presented.
Issue
Whether or not the RTC has jurisdiction to levy on respondent’s real property.
Held
YES. The levy of the respondent’s property was made pursuant to the RTC orders issued in the exercise of its equity jurisdiction, independent of the ejectment case originally filed with the MTC.
The appellate jurisdiction of courts is conferred by law. The appellate court acquires jurisdiction over the subject matter and parties when an appeal is perfected.
On the other hand, equity jurisdiction aims to provide complete justice in cases where a court of law is unable to adapt its judgments to the special circumstances of a case because of a resulting legal inflexibility when the law is applied to a given situation. The purpose of the exercise of equity jurisdiction, among others, is to prevent unjust enrichment and to ensure restitution.
In this case, the RTC’s equity jurisdiction is separate and distinct from its appellate jurisdiction on the ejectment case. The RTC could not have issued its orders in the exercise of its appellate jurisdiction since there was nothing more to execute on the dismissed ejectment case. As the RTC orders explained, the dismissal of the ejectment case effectively and completely blotted out and cancelled the complaint.
Hence, the RTC orders were clearly issued in the exercise of the RTC’s equity jurisdiction, not on the basis of its appellate jurisdiction.