TOPIC Judgments

CASE NO. G.R. No. 154282

CASE NAME Barrazona v. RTC Baguio
MEMBER Robyn Bangsil

DOCTRINE
1. Trial courts are must not issue minute orders or resolutions.
2. A trial court should state in its order the reasons for the dismissal of the complaint so that when the
order is appealed, the appellate court can readily determine from a casual perusal thereof whether
there is a prima facie justification for the dismissal.
3. Under Section 3, Rule 16 of the 1997 Rules of Civil Procedure, as amended, we require that
resolutions disposing of a motion to dismiss shall state clearly and distinctly the reasons therefor.

RECIT-READY DIGEST
Vangie Barrazona leased portions of a San-an Realty and Development Corporation’s building. Barrazona
then defaulted in the payment of rentals despite demands by respondent. San-an Realty filed with RTC of
Baguio, a Complaint for Collection of Sum of Money with Damages. Barrazona filed a MTD alleging
that RTC has no jurisdiction, because it is actually a complaint for ejectment, which is under the
jurisdiction of the MTC. RTC denied MTC for lack of merit in an order. Petitioner filed this Petition for
Certiorari alleging: (1) the RTC committed GADALEJ in denying her Motion to Dismiss; and (2) the
Resolution denying her Motion to Dismiss is unconstitutional as it does not state its legal basis. SC
granted the petition because the RTC erred by dismissing the motion in a minute order. (See doctrine!)

FACTS
- Vangie Barrazona has been leasing portions of a building at Baguio City owned by San-an Realty and
Development Corporation.
- Barrazona defaulted in the payment of the monthly rentals and failed to pay despite demands by
respondent.
- San-an Realty filed with the RTC of Baguio, a Complaint for Collection of Sum of Money with
Damages.
- Barrazona then filed with the RTC a Motion to Dismiss on the ground that the RTC has no
jurisdiction over the complaint because the allegations indicate that the action is for ejectment (illegal
detainer), which is under the exclusive jurisdiction of the MTC.
- However, the RTC denied the Motion to Dismiss for lack of merit in an order.
- Petitioner filed this Petition for Certiorari alleging: (1) the RTC committed GADALEJ in denying her
Motion to Dismiss; and (2) the Resolution denying her Motion to Dismiss is unconstitutional as it
does not state its legal basis.

ISSUE/S and HELD

1. WoN the Order of the RTC denying her Motion to Dismiss violates the Constitution as it does not
state the facts and the law on which it is based? YES
2. WoN RTC has jurisdiction? NO, MTC has jurisdiction (not discussing this tho bc it’s not related to
the main topic & you should already know it by heart at this point)

RATIO
- Trial courts must not issue minute orders or resolutions like the one in this case. (Reproduction of the
assailed order is in the notes portion!)
- A trial court should state in its order the reasons for the dismissal of the complaint so that when the
order is appealed, the appellate court can readily determine from a casual perusal thereof whether
there is a prima facie justification for the dismissal.

1
- Under Section 3, Rule 16 of the 1997 Rules of Civil Procedure, as amended, we require that
resolutions disposing of a motion to dismiss shall state clearly and distinctly the reasons therefor.
Sec. 3. Resolution of motion. — After the hearing, the court may dismiss the action or claim, deny
the motion, or order the amendment of the pleading. The court shall not defer the resolution of the
motion for the reason that the ground relied upon is not indubitable.
- In every case, the resolution shall state clearly and distinctly the reasons therefor.
o This requirement proscribes the common practice of perfunctorily dismissing a motion to
dismiss for "lack of merit."
o Such cavalier dispositions can often pose difficulty and misunderstanding on the part of
the aggrieved party in taking recourse therefrom and likewise on the higher court called
upon to resolve the same, usually on certiorari.
- While an order denying a motion to dismiss is non-appeallable, however, if the denial is in excess of
jurisdiction, certiorari and prohibition are proper remedies from such order of denial.

DISPOSTIVE PORTION
The petition is GRANTED. The Order dated June 19, 2002 issued by the RTC, Branch 61, Baguio City,
in Civil Case No. 5238-R, is ANNULLED and SET ASIDE.

NOTES
ORDER
This Court finds that the grounds stated in the Motion to Dismiss to be without merit, hence, the same is
denied.
SO ORDERED.