Case Digest (G.R. No. 168139)
Facts:
The case involves Ferdinand S. Agustin as the petitioner and spouses Mariano and Presentacion Delos Santos as the respondents. The events leading to the case began in 1990 when Agustin started occupying one of the apartment units owned by the Delos Santos couple located at 230 Manrique Street, Sampaloc, Manila, for a monthly rent of P2,000.00. This rent was increased to P2,300.00 in May 1999. On May 10, 2000, the respondents filed a complaint for ejectment against Agustin before the Metropolitan Trial Court (MeTC) of Manila, claiming they needed the apartment for their daughter’s children who would be studying at the University of Santo Tomas. The MeTC dismissed the complaint on January 9, 2002, for lack of cause of action, stating that the respondents failed to comply with the requirements for ejectment based on personal need. This decision became final and was enforced by the respondents through the collection of rent.
Subsequently, on October 10, 2002, the respondents is...
Case Digest (G.R. No. 168139)
Facts:
Ownership and Lease Agreement
- Respondents, spouses Mariano and Presentacion delos Santos, are the lawful owners of apartment units located at 230 Manrique Street, Sampaloc, Manila.
- Petitioner Ferdinand Agustin has continuously occupied one of the apartment units since 1990, paying a monthly rent of P2,000.00, which was increased to P2,300.00 in May 1999.
First Ejectment Case (Civil Case No. 167142-CV)
- On May 10, 2000, respondents filed a complaint for ejectment against petitioner before the Metropolitan Trial Court (MeTC) of Manila, Branch 22.
- The ground for ejectment was the respondents' personal need to repossess the apartment unit for their daughter's children, who would be studying at the University of Sto. Tomas.
- On January 9, 2002, the MeTC dismissed the complaint for lack of cause of action, as respondents failed to comply with the requirements for ejectment based on personal need. The court, however, allowed respondents to collect the monthly rent and a 15% increase as per the Rent Control Law.
Second Ejectment Case (Civil Case No. 174168)
- After the first case, respondents sent a Notice of Termination dated October 10, 2002, informing petitioner of the termination of the verbal month-to-month lease and giving him 30 days to vacate.
- Petitioner failed to vacate, prompting respondents to file a second ejectment case on the ground of termination of the lease contract.
- On June 12, 2003, the MeTC, Branch 15, ruled in favor of respondents, ordering petitioner to vacate the premises and pay fair rental value of P5,000.00 per month from the date of filing the complaint, plus attorney’s fees.
Appeal to the Regional Trial Court (RTC)
- The RTC reversed the MeTC decision, ruling that the second ejectment case was barred by res judicata, as the first case had already been decided on the merits. The RTC also held that the fair rental value should not exceed P2,530.00 per month.
Appeal to the Court of Appeals (CA)
- The CA partially reversed the RTC decision, holding that the two ejectment cases involved different causes of action and that res judicata did not apply. The CA ruled that the lease contract was on a month-to-month basis and had expired, thus ordering petitioner to vacate the premises.
Issue:
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Ruling:
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Ratio:
- Res Judicata: The principle of res judicata requires identity of parties, subject matter, and causes of action. In this case, the two ejectment cases involved different causes of action (personal need vs. expiration of lease) and different subject matters (separate lease contracts for different periods). Thus, res judicata did not apply.
- Expiration of Lease Contract: The lease contract was verbal and on a month-to-month basis, which is considered a lease with a definite period that expires at the end of each month. The notice of termination validly ended the lease, and petitioner’s continued possession became unlawful.
- Novation: Novation requires a clear and unequivocal intent to replace or modify the existing obligation. The acceptance of rental payments by respondents did not amount to novation, as there was no evidence of intent to novate the lease contract.