FACTS:

Petitioner Victoria D. Bayubay filed an ejectment case against private respondent Big Mak Burger for expiration of the lease contract. Private respondent argued that it had the option to renew the lease contract and raised the defense of estoppel. The Municipal Trial Court (MTC) issued summons under the Rule on Summary Procedure and rendered a decision in favor of the petitioner. The private respondent appealed to the Regional Trial Court (RTC), alleging violation of due process by the MTC. The RTC affirmed the decision, but the Court of Appeals reversed it and remanded the case to the MTC for further proceedings.

ISSUES:

1. Whether the failure of the MTC to allow the private respondent to submit position papers and affidavits of witnesses constituted a denial of due process.

2. Whether the questions raised in the case were purely questions of law or required submission of affidavits and evidence.

3. Whether there was a necessity for the MTC to issue an order following the close of the pre-trial conference.

RULING:

1. The Supreme Court upheld the decision of the Court of Appeals to remand the case to the MTC for further proceedings. The MTC failed to comply with the mandatory provisions of the Rule on Summary Procedure regarding the preliminary conference and submission of affidavits. The MTC did not issue an order clarifying and defining the issues of the case, which deprived the parties of their opportunity to submit their position papers and affidavits within the prescribed ten-day period. The Court emphasized that both substantive and procedural rights are guaranteed by due process, and compliance with procedural rules is essential for the orderly administration of justice and protection of substantive rights. The petition was denied, and costs were imposed on the petitioner.