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AZUCENA GO v. CA

FACTS:

The case involves a petition for review on certiorari seeking to set aside the consolidated Decision of the Court of Appeals (CA) in two cases. The Court of Appeals disallowed the suspension of the ejectment proceedings and declared certain orders null and void. The undisputed facts, as found by the Respondent Court, are as follows:

The private respondent filed an ejectment case against the petitioners before the Municipal Trial Court in Cities (MTCC) of Iloilo City. The MTCC issued an order holding in abeyance the preliminary conference in the ejectment case until after the case for specific performance involving the same parties is finally decided by the RTC. The private respondent appealed this order to the RTC, which denied the petitioners' motion to dismiss the appeal. The petitioners then filed a motion for reconsideration, which was also denied. The petitioners filed a petition for certiorari, assailing the denial of the motion to dismiss the appeal. Meanwhile, the private respondent filed a motion to resume proceedings, which the RTC granted and ordered the remand of the records to the MTCC for further proceedings. The petitioners filed a motion for reconsideration and clarification, which was also denied. The petitioners then filed another petition for review, questioning the RTC's order to resume proceedings before the MTCC. The court issued a temporary restraining order, and the case was eventually brought before the Supreme Court through a petition for review on certiorari.

ISSUES:

  1. Whether the Court of Appeals erred in allowing the appeal of an interlocutory order.

  2. Whether the Court of Appeals erred in not applying the exceptions provided for in the Vda. de Legaspi and Wilmon cases, allowing the suspension of the ejectment case based on strong reasons of equity or when the right of the private respondent to the property in question is seriously placed in issue.

RULING:

  1. The Court held that while the appealed order is indeed interlocutory and typically not subject to appeal, the unique procedural void in this case warranted a treat of the appeal as a petition for certiorari under Rule 65. This approach was necessary to avoid undue delays and ensure an expeditious resolution of the case, consistent with the objective of the Rules on Summary Procedure.

  2. The Court found that the exceptions provided for in Vda. de Legaspi and Wilmon were not applicable. The resolution of the ejectment suit would not result in the demolition of the premises, and therefore, no "strong reasons of equity" exist that would justify the suspension of the ejectment proceedings.

PRINCIPLES:

  • Interlocutory orders are not typically subject to appeal.

  • Certiorari may be allowed in exceptional cases where interlocutory orders are patently erroneous and ordinary appeal does not offer an adequate remedy.

  • Courts may suspend rules if their rigid application frustrates justice and becomes counterproductive.

  • In ejectment cases, the lower courts have the competence to resolve issues of ownership only to determine the issue of possession, and whatever pronouncements they make on ownership are provisional.

  • Exceptions to the general rule against the suspension of ejectment proceedings require strong reasons of equity, such as those in Vda. de Legaspi, which are not present if the premises are not under threat of demolition from the ejectment ruling.