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Catungal v.

Hao (Short title) ISSUE/S


GR # 134972 | March 22, 2001 1. W/N CA erred in reversing the findings of the RTC by using as basis for
Petitioner: Sps. Ernesto and Mina Catungal reducing the rental only the evidence submitted by the parties and
Respondent: Doris Hao ignoring circumstances of which the RTC properly took judicial notice.
(Rule 129, Section 2)
PROVISIONS
DOCTRINE
Judicial cognizance is taken only of those matters that are commonly known. Rule 129, Section 2
The power of taking judicial notice is to be exercised by courts with caution; Judicial notice, when discretionary. — A court may take judicial notice of
care must be taken that the requisite notoriety exists; and every reasonable matters which are of public knowledge, or are capable to unquestionable
doubt on the subject should be promptly resolved in the negative. demonstration, or ought to be known to judges because of their judicial
functions. (1a)
FACTS
RULING & RATIO
- Galang, leased a three-storey building situated at Baclaran to BPI 1. Yes
for a period of15 years and during the existence of the lease, BPI - In ruling that the increased rental should be awarded, RTC based
subleased the ground floor to Hao. its decision on the doctrine of judicial notice.
- Galang and Hao executed a contract of lease on the second and - The Court a quo misappreciated the nature of the property, its
third floors of the building. and spouses Catungal subsequently location and the business practice in the vicinity and indeed
bought the property from Galang. committed an error in fixing the amount of rentals.
- Invoking her right of first refusal purportedly based on the lease, - According to jurisprudence, the trial court had the authority to fix the
Hao filed a complaint for Annulment of Sale with RTC Makati. reasonable value for the continued use and occupancy of leased
- Meanwhile, the lease agreement between BPI and Galang expired. premises after the termination of the lease contract, and that it was
so Spouses Catungal sent demand letters to Hao to vacate. not bound by the stipulated rental in the contract of lease.
- The demand letters were unheeded causing the spouses to file two - The RTC correctly applied the legal concept of judicial notice
complaints for ejectment, with MeTC Paranaque. - Judicial knowledge may be defined as the cognizance of certain
o Hao then filed an action for injunction with RTC of Makati, facts which a judge under rules of legal procedure or otherwise may
to stop the MeTC of Paranaque from proceeding. properly take or act upon without proof because they are already
- The cases were consolidated with RTC of Makati which rendered a known to him, or is assumed to have, by virtue of his office.
decision granting the injunction and annulling the contract of sale. - Judicial cognizance is taken only of those matters that are
- On appeal, CA reversed and set aside the decision of the RTC and commonly known. The power of taking judicial notice is to be
the complaints were accordingly dismissed. exercised by courts with caution; care must be taken that the
- Hao elevated the case before the SC which denied the same. requisite notoriety exists; and every reasonable doubt on the
- The MeTC Paranaque, after the reversal of the decision for subject should be promptly resolved in the negative.
injunction, proceeded with the trial of the ejectment cases and - Matters of judicial notice have three requisites: (1) matter must be
rendered a Decision ordering Hao to vacate. one of common and general knowledge; (2) must be well and
- Spouses Catungal filed a motion for clarificatory judgment on the authoritatively settled and not doubtful or uncertain (3) it must be
ground that MeTC only awarded rent for the ground floor. MeTC known to be within the limits of jurisdiction of the court.
clarified that the payment was only for the use of the first floor. - The RTC correctly took judicial notice of the nature of the leased
- Spouses sought reconsideration, praying that Hao be ordered to property subject of the case at bench based on its location and the
pay the use all floors and Hao. commercial viability.
- Instead of resolving the motion for reconsideration, the MeTC of
issued an Order, elevating the case to the RTC. DISPOSITION
- RTC of Paranaque ordered that the rentals should covers all floors. WHEREFORE, premises considered, judgment is hereby rendered in favor
- CA reduced the amount of rentals for the second and third floors. of petitioners by reinstating the decision of the RTC, with modifications.