Facts:
In 1998, Intramuros Administration (Intramuros) entered into lease agreements with
Offshore Construction and Development Company (Offshore Construction) for three
properties: Baluarte De San Andres, Baluarte De San Francisco De Dilao, and Revellin
De Recoletos. The leases were for a period of five years, from September 1, 1998, to
August 31, 2003, with provisions for renewal upon mutual agreement. Offshore
Construction occupied the properties and made improvements but faced issues with
compliance with architectural standards mandated by Presidential Decree No. 1616,
leading to a halt in its projects.
In 1999, a Compromise Agreement was executed, affirming the validity of the lease
contracts while terminating the lease for Revellin De Recoletos. The agreement specified
the areas Offshore Construction could occupy and required it to relocate certain
structures. Despite the agreements, Offshore Construction failed to pay utility bills and
rental fees, accumulating arrears totaling over P13 million by December 31, 2009.
On April 28, 2010, Intramuros filed a Complaint for Ejectment against Offshore
Construction due to non-payment of rent. Offshore Construction responded with a motion
to dismiss, claiming forum shopping, lack of jurisdiction, and litis pendentia, citing two
pending cases related to the same properties. The Metropolitan Trial Court dismissed
Intramuros' complaint, ruling that it lacked jurisdiction and that Intramuros had
committed forum shopping.
Intramuros appealed the dismissal to the Regional Trial Court, which upheld the
Metropolitan Trial Court's decision. Intramuros subsequently filed a Petition for Review
on Certiorari with the Supreme Court, challenging the findings of forum shopping and
jurisdiction.
Issues:
1. Whether or not the direct resort to the Supreme Court was proper?
2. Whether or not the Metropolitan Trial Court had jurisdiction over the ejectment
complaint?
3. Whether or not Intramuros committed forum shopping by filing the ejectment
complaint despite pending cases?
Ruling:
The Supreme Court granted the Petition for Review, reversing the decision of the lower
courts. The Court held that:
1. Direct Resort to the Supreme Court: The Court found that direct resort was
warranted due to the nature of the issues raised, which were primarily questions of
law.
2. Jurisdiction of the Metropolitan Trial Court: The Court ruled that the
Metropolitan Trial Court had jurisdiction over the ejectment complaint. The sole
issue in ejectment proceedings is the determination of physical possession, and
the allegations in Intramuros' complaint satisfied the requirements for an unlawful
detainer action.
3. Forum Shopping: The Court concluded that Intramuros did not commit forum
shopping. The pending cases did not involve the same rights or reliefs as the
ejectment case, and a judgment in one would not affect the others.
