Facts:

The case at hand involves two consolidated petitions for review on certiorari under Rule 45 of the Revised Rules of Court, decided on October 19, 1999, by the Third Division of the Supreme Court of the Philippines. The petitioners in G.R. No. 106029 are Benjamin S. Abalos and Arsenio Arellano, while Oscar C. Fernandez is the petitioner in G.R. No. 105770. The respondents include the Honorable Court of Appeals and private individuals Fredisvinda Fernandez, Sergio Fernandez, Genoveva Coquia, Fausto Meneses, and Oscar Fernandez.

The dispute centers around Dupo Fishpond, located in Dagupan City and Binmaley, Pangasinan, co-owned by the respondents and Oscar Fernandez among others. Fredisvinda Fernandez, acting as the administratrix of the fishpond, leased it to Oscar Fernandez for five years, from July 1, 1979, until June 30, 1984. Subsequently, Oscar Fernandez subleased the property to Benjamin Abalos and hired Arsenio Arellano as a caretaker. Near the lease's original expirat

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Facts:

Background of the Property and Parties

• The subject matter involves the Dupo Fishpond (also referred to as a Fishponda) located in Dagupan City and Binmaley, Pangasinan, which is owned in co-ownership by private respondents Fredisvinda Fernandez, Fausto Meneses, Sergio Fernandez, and Genoveva Coquia, among others.
• Several petitioners are involved in the chain of lease and sublease agreements concerning the fishpond:
• Fredisvinda Fernandez, acting as administratrix, executed a lease agreement of the fishpond to petitioner Oscar Fernandez for a period from July 1, 1979, to June 30, 1984.
• Petitioner Oscar Fernandez, in turn, subleased the fishpond to petitioner Benjamin Abalos.
• Petitioner Benjamin Abalos hired petitioner Arsenio Arellano as caretaker of the fishpond.

Lease Extensions and Bidding Process

• As the lease period neared its expiration, petitioner Oscar Fernandez pleaded for an extension which was granted for one (1) year, extending the lease period up to June 30, 1985.
• On August 26, 1984, the fishpond was offered in a bidding process among all co-owners for its lease starting on July 1, 1985.
• Jorge Coquia, through his son Anthony, won the bid with a price of P250,000.00.
• Petitioner Fernandez’s bid was significantly lower at P151,000.00.
• Subsequently, petitioner Fernandez informed his sublessees that he had lost the bidding process.

Possession and Legal Dispute

• On July 1, 1985, after the expiration of the initial lease period, Anthony Coquia along with Dagupan City police authorities attempted to take possession of the fishpond.
• Petitioner Arellano refused to vacate on the ground that he had yet to receive instructions from petitioner Abalos.
• Demands were sent for the petitioners to surrender possession to the rightful private respondents, but these demands were ultimately ignored.
• On April 15, 1986, the private respondents instituted a Complaint for unlawful detainer (Civil Case No. 7127) before Branch 3 of the Municipal Trial Court in Cities (MTCC) of Dagupan City.
• Petitioners Abalos and Arellano filed an Answer denying the complaint and asserting that the lease had been renewed for an additional five (5) years (from July 1, 1984, to June 30, 1989) with an escalation clause.
• They further alleged that petitioner Fernandez and other co-owners had received advance rentals for the sublease.
• A cross-claim was also filed by petitioners Abalos and Arellano against petitioner Fernandez, seeking reimbursement in the event of an adverse judgment.

Proceedings in Lower Courts

• MTCC Decision (July 25, 1989):
• The lower court ordered petitioners Oscar Fernandez and Benjamin Abalos, jointly and severally, to pay the private respondents:
• P250,000.00 per year as reasonable compensation for the fishpond from July 1, 1985 until the date of vacation (noted as March, 1988 in subsequent proceedings).
• Attorney’s fees amounting to P3,000.00.
• Costs.
• The complaint against petitioner Arellano and the cross-claim against petitioner Fernandez were dismissed.
• Regional Trial Court (RTC) Decision (March 21, 1991):
• The RTC reversed the MTCC decision on the ground of lack of jurisdiction by holding that the case involved the interpretation of the lease renewal, which was not amenable to pecuniary estimation.
• However, the portions dismissing the complaint against petitioner Arellano and the cross-claim against petitioner Fernandez were affirmed.
• Court of Appeals (CA) Decision (February 17, 1992):
• The CA set aside the RTC’s reversal and affirmed the MTCC decision in toto.
• Subsequent motions for reconsideration by petitioners filed with the CA were denied.

Consolidated Petitions on Certiorari

• Two consolidated petitions for review on certiorari were filed (G.R. Nos. 106029 and 105770) challenging the CA decision.
• The petitioners raised the following errors:
• CA erred in not holding that there was a valid renewal of the lease agreement for another five years.
• CA erred in holding petitioner Abalos jointly and severally liable with petitioner Fernandez for the payment of P250,000.00 per year.
• CA erred in dismissing the cross-claim of petitioner Abalos against petitioner Fernandez.
• Additionally, petitioner Fernandez claimed that he had provided prior notice (via letters) warning of the need to vacate the fishpond.

Issue:

Lease Renewal

• Whether there was a renewal of the lease agreement for petitioner Abalos over the fishpond for an additional five-year term from July 1, 1984, to June 30, 1989.
• Whether the alleged addendum (Exhibit a4a) serves as sufficient proof of renewal given that it was signed solely by Corazon Fernandez in her capacity as administratrix and not by all co-owners.

Joint and Several Liability

• Whether petitioners Fernandez and Abalos are jointly and severally liable for the yearly rental payment of P250,000.00 from July 1, 1985, to March 1988, as compensation for the fishpond.
• Whether the actions taken by both parties in failing to vacate after the expiration of their respective lease agreements warrant such liability.

Dismissal of the Cross-Claim

• Whether the dismissal of petitioner Abalos’ cross-claim against petitioner Fernandez was proper.
• Whether the advanced rental payments and the communication from petitioner Fernandez indicating the termination were sufficient to preclude the recovery sought by petitioner Abalos.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)