Roman Catholic Archbishop of Manila v. Court of Appeals

G.R. No. 111324 (July 5, 1996)

Facts:

The case arises from a lease agreement executed on August 1, 1985, between the Roman Catholic Archbishop of Manila (petitioner) and spouses Ernesto and Lorna Reyes (respondents) concerning a parcel of land in Intramuros, Manila, measuring 470.30 square meters. The lease was for ten years, with an option to renew for another ten years, and included a graduated rental fee schedule starting at P4.50 per square meter, increasing to P6.50 by the ninth and tenth years. The lease also granted the Reyes spouses a right of pre-emption to purchase the property if the petitioner decided to sell.

In 1987, the Reyes spouses discovered that an adjacent property owner's concrete fence encroached upon 30.96 square meters of the leased land. They requested the petitioner to rectify this encroachment but received no response. Consequently, they withheld rental payments as leverage to compel the petitioner to address the issue.

On March 9, 1987, the petitioner expressed an intention to sell the property, and although the Reyes spouses showed interest, no agreement was reached. In 1989, the petitioner demanded payment of P68,000 for unpaid rentals from October 1986 to January 1989, to which the Reyes spouses responded by reiterating their desire to purchase the property, contingent upon the resolution of the encroachment issue.

The petitioner later offered to sell the property at P2,127.45 per square meter, while the Reyes spouses argued that they should be allowed to purchase it at P1,600.00 per square meter, the price from 1987. Unable to reach an agreement, the Reyes spouses filed a complaint for specific performance and damages in the Regional Trial Court of Manila, asserting two causes of action: (1) for the correction of the encroachment issue, and (2) to compel the petitioner to sell the property at the previously agreed price.

The petitioner filed a motion to dismiss, which was partially granted by the trial court, allowing the first cause of action to proceed but dismissing the second. The trial court later issued a partial judgment ordering the Reyes spouses to pay P108,297.31 in rental arrears, which they appealed to the Court of Appeals.

Legal Issues:

1. Whether the appeal involved multiple appeals requiring a record on appeal for perfection.
2. Whether the appeal raised purely questions of law.
3. Whether the Court of Appeals had jurisdiction over the appeal from the Regional Trial Court.

Arguments:

• Petitioner’s Arguments:

  • The case involved multiple appeals due to the separate orders issued by the trial court, necessitating a record on appeal for the perfection of the appeal.
  • The issues raised were purely questions of law, which should have been elevated directly to the Supreme Court, as the trial court's decisions were based solely on the pleadings without the need for factual determinations.

• Respondents’ Arguments:

  • The appeal did not involve multiple appeals but was a single appeal concerning the same cause of action.
  • The issues raised included factual questions regarding the existence of a contract of sale and the propriety of the trial court's judgment on the pleadings, which warranted the Court of Appeals' jurisdiction.

Court’s Decision and Legal Reasoning:

The Court affirmed the decision of the Court of Appeals, ruling that the case did not involve multiple appeals requiring a record on appeal. The issues raised by the respondents were not purely questions of law but included factual inquiries that the Court of Appeals was competent to resolve. The Court emphasized that the disputes arose from the same cause of action concerning the lease agreement and the encroachment issue, thus negating the need for multiple appeals.

The Court also clarified that while appeals from the Regional Trial Court raising only questions of law should be directed to the Supreme Court, the issues in this case involved factual determinations, making the Court of Appeals the proper venue for the appeal. The Court reiterated that the trial court's findings regarding the lack of a perfected contract of sale and the judgment on rental arrears were not purely legal questions but required examination of the facts.

Significant Legal Principles Established:

1. The principle that multiple appeals are not necessary when the issues arise from the same cause of action, even if there are separate orders from the trial court.
2. The distinction between questions of law and questions of fact, with the latter requiring factual determinations that fall within the jurisdiction of the Court of Appeals.
3. The procedural requirement that appeals involving factual issues should be directed to the Court of Appeals, while those involving purely legal questions may be elevated to the Supreme Court.