TOPIC: HIERARCHY OF COURTS

INTRAMUROS ADMINISTRATION

vs.

OFFSHORE CONTRUCTION DEVELOPMENT COMPANY

G.R. No. 196795, March 07, 2018

FACTS:

Intramuros Administration leased certain real properties of the national government,

which it administered to Offshore Construction. Offshore then subleased these properties. All
the lease contracts included a provision for lease renewals every five (5) years upon the parties’
mutual agreement.

Offshore Construction occupied and introduced improvements in the leased premises.

However, Intramuros and Department of Tourism halted the projects due to Offshore
Construction’s non-conformity with PD No. 1616 which required 16 th to 19th centuries’ Philippine
–Spanish Architecture in the area. Consequently, Offshore Construction filed a complaint with
prayer for preliminary injunction and temporary restraining order against Intramuros and the
Department of Tourism before the Manila RTC. Parties later on entered into a Compromise
Agreement which the Manila RTC approved. The compromise agreement retained the five-year
period of the existing lease contract and stated the areas that may be occupied by Offshore
Construction. During the lease period, Offshore Construction failed to pay its utility bills and
rental fees, despite several demand letters. Intramuros tolerated the continuing occupation,
hoping that Offshore Construction would pay its arrears. To settle its arrears, Offshore
Construction proposed to pay the Department of Tourism's monthly operational expenses for
lights and sound equipment, electricity, and performers at the Baluarte Plano Luneta de Sta.
Isabel. Intramuros and the Department of Tourism accepted the offer.
However, Offshore Construction continued to fail to pay its arrears. Intramuros filed a
Complaint for Ejectment before the Manila Metropolitan Trial Court. Offshore Construction filed
a Motion to dismiss on the grounds of violation on rule on non-forum shopping, lack of
jurisdiction over the case and litis pendentia. MTC granted the motion to dismiss which was
affirmed in toto by the RTC. Intramuros through the Office of the OSG filed a petition for
review on certitorari with the Supreme Court. Offshore Construction argues that the Petition for
review should be dismissed because it violates the principle of hierarchy of courts and raises
questions of fact namely the expiration of the contracts of lease and the business concession in
favour of the Offshore Construction.

ISSUE:

1. Whether or not there was a violation of principle of hierarchy of courts in this case?
RULING:

The Supreme Court held that although petitioner Intramuros’ direct resort to it instead
of the Court of Appeals for intermediate review violates the principle of hierarchy of courts, the
said principle is not inviolabe. The Supreme Court stated that one of the exceptions is the
exigency of the situation being litigated. Here, the controversy between the parties has been
dragging on since 2010, which should not be the case when the initial dispute—an ejectment
case—is, by nature and design, a summary procedure and should have been resolved with
expediency.
Moreover, the Supreme Court’s rules of procedure permit the direct resort to it from a decision
of the Regional Trial Court upon questions of law, such as those which petitioner raises in this
case. The questions of law that were raised in the case are whether the MTC has jurisdiction
over the subject matter of the complaint and whether there was a forum shopping.

Moreover, a direct recourse to the Supreme Court can be taken for a review of the
decisions, final orders or resolutions of the RTC, but only on questions of law. Under Section 5
of Article VIII of the Constitution, the Supreme Court has the power to:

(2) Review, revise, reverse, modify, or affirm on appeal or certiorari as the law or the
Rules of Court may provide, final judgments and orders of lower courts in:
....

(e) All cases in which only an error or question of law is involved.

This kind of direct appeal to this Court of RTC judgments, final orders or resolutions is
provided for in Section 2(c) of Rule 41, which reads:

SEC. 2. Modes of appeal. —

....

(c) Appeal by certiorari. — In all cases where only questions of law are raised or
involved, the appeal shall be to the Supreme Court by petition for review on certiorari in
accordance with Rule 45. Procedurally then, petitioners could have appealed the RTC
Decision affirming the MTC (1) to the Supreme Court on questions of law only; or (2) if
there are factual questions involved, to the CA — as they in fact did.

Hence, petitioner's resort to the Supreme Court is proper and warranted under the
circumstances.