Case Digest (G.R. No. 110223)
Facts:
On November 29, 1989, the City of Manila filed an action for ejectment against Army and Navy Club of Manila, Inc. before the Metropolitan Trial Court of Manila, Branch 17. The complaint alleged that the City owned the subject land and improvements known as the Army and Navy Club of Manila, and that petitioner occupied the premises under a contract of lease executed in January 1983, but failed to pay rents and realty taxes and to construct a modern multi-storied hotel within the contract periods; the City rescinded and demanded vacating through a letter dated May 24, 1989.
The MTC rendered a summary judgment ordering eviction and payment of rental arrearages with legal interest. The Regional Trial Court affirmed in toto, and the Court of Appeals dismissed petitioner’s appeal. Petitioner then argued, among others, that the property’s alleged historical-landmark status under R.A. No. 4846 (as amended by P.D. No. 374) should bar ejectment, and that it was denied due process because of the summary judgment and the refusal to admit an amended answer.
Issues:
- Whether petitioner’s ouster violated its claimed status as a historical landmark.
- Whether the Court of Appeals erred in affirming the denial of admission of petitioner’s amended answer.
- Whether the Court of Appeals erred in affirming the summary judgment.
- Whether petitioner was denied due process by the grant of summary judgment.
- Whether the property being allegedly of public domain rendered the lease void.
Ruling:
The Court affirmed the Court of Appeals and denied the petition for lack of merit, holding that the ejectment case depended on the lease and petitioner’s contractual breaches. It ruled that the historical-landmark certification did not grant possessory rights or authority to avoid the lease obligations, and that the City’s ownership and petitioner’s lease relationship barred inconsistent denial.
The Court further held that the summary judgment was proper because petitioner’s admissions and pleadings showed no genuine triable issue of material fact, and that the amended answer was correctly denied for being filed late and for presenting defenses contradictory to the original answer, contrary to the rules of procedure. It also rejected the claim of denial of due process, and found no reversible error in the lower courts’ handling of the case.
Ratio:
The Court found Article 1673 of the Civil Code applicable: the lessor may eject the lessee for lack of payment, violation of contractual conditions, and similar grounds. Petitioner admitted the lease, acknowledged its failures to pay rents and realty taxes and to construct the hotel, and the Court concluded that rescission and eviction followed from the lease violations.
On petitioner’s historical-landmark argument, the Court explained that R.A. No. 4846 and P.D. No. 374 express a policy to preserve cultural properties and regulate their restoration and preservation under the supervision of the National Museum, and that the referenced designation does not, by itself, vest ownership or possessory rights to a private lessee. Even if the historical recognition were valid, eviction remained justified if lease obligations were breached.
As to procedure, the Court reiterated that summary judgment is proper when there is no genuine issue of material fact. It held that petitioner’s defenses did not create substantial triable issues, and that the amended answer was properly disallowed because it was filed one year after the original answer and raised defenses inconsistent with the earlier admissions, defeating the purpose of the pleading rules.
Doctrine:
- Article 1673 of the Civil Code authorizes judicial ejectment for, among others, lack of payment of the stipulated price and violation of conditions agreed upon in the contract.
- A summary judgment may be granted when the pleadings and admissions show no genuine triable issue of material fact (except possibly as to damages).
- Defenses raised through an amended answer that is late and inconsistent with the original admissions contravene the rules of procedure and may be denied.
- A party who has treated the lessor as owner and benefited from the lease cannot later assume an inconsistent position to deny the lessor’s ownership to avoid contractual obligations.
- Under R.A. No. 4846 (as amended by P.D. No. 374), historical or cultural recognition does not automatically grant possessory rights that defeat otherwise valid ejectment based on lease violations; preservation and restoration remain subject to statutory supervision.