Case Digest (G.R. No. 143361)
Facts:
In Ballesteros v. Abion, the petitioner, Paulo Ballesteros, leased one door of a two-door, three-story commercial building and the underlying 229-sq.m. lot in Iriga City from Ronald Vargas on March 14, 1991, under a contract valid until April 1, 1996. The property was originally owned by Ruperto Ensano (TCT No. 6178), transferred to the Development Bank of the Philippines (DBP), then sold to Dr. Rodolfo Vargas on March 30, 1988, but registered only on February 21, 1996 (TCT Nos. 941 and 942). On September 27, 1995, Dr. Vargas sold the same property to respondent Rolando Abion (TCT No. 949, April 10, 1996). Despite Petitioner’s knowledge of respondent’s title, on October 30, 1995, he entered into a second five-year lease with Ronald Vargas for both doors, paid rent in advance until June 1997, and sought registration of this lease, which was refused, being entered only in the primary book. Respondent demanded possession by letters dated April 25 and June 20, 1996. After PetitionerCase Digest (G.R. No. 143361)
Facts:
- Property and ownership transfers
- The subject is a two-door, three-story commercial building on a 229 sqm lot originally owned by Ruperto Ensano (TCT No. 6178).
- Ensano transferred ownership to the Development Bank of the Philippines (DBP), which sold it to Dr. Rodolfo Vargas on March 30, 1988 (deed of absolute sale).
- Registration in their names (TCT Nos. 941 and 942) only occurred on February 21, 1996.
- Lease transactions by petitioner
- On March 14, 1991, petitioner leased one door from Ronald Vargas (Dr. Vargas’s son), who misrepresented himself as owner; term until April 1, 1996; unregistered.
- On October 30, 1995, petitioner entered a new five-year lease (Nov 1, 1995–Nov 1, 2000) covering both doors, again with Ronald Vargas; advance rents paid to June 1997; attempt to register yielded only a primary entry.
- Sale to respondent and demands to vacate
- Dr. Vargas sold the property to respondent on September 27, 1995 (deed of absolute sale); TCT No. 949 in respondent’s name issued April 10, 1996.
- Respondent’s letters dated April 25 and June 20, 1996 demanded that petitioner vacate; petitioner refused.
- Unlawful detainer proceedings
- Respondent filed unlawful detainer on September 4, 1996 in MTCC Iriga City—dismissed for failure to state cause.
- On appeal, RTC Iriga City, Branch 37 reversed: ordered ejectment, P50,000 attorney’s fees, and P7,000 monthly rent from September 1995 until vacation; issued writ of execution December 1, 1997.
- Petitioner’s motions for time to vacate denied (Dec 9 & 11, 1997); sheriff forcibly executed on December 15, 1997.
- Court of Appeals and Supreme Court petition
- CA affirmed July 15, 1999 with modifications: held second lease void; possession by tolerance; reduced attorney’s fees to P20,000; reduced rent to P5,000/month (July 1–Dec 15, 1997).
- Reconsideration denied May 25, 2000; petitioner filed SC review raising multiple issues.
Issues:
- Lease and ejectment
- Was respondent’s ejectment of petitioner and termination of the lease lawful?
- Cause of action and jurisdiction
- Did respondent establish a cause of action for unlawful detainer?
- Did the MTCC have jurisdiction to try the case?
- Notice and good faith
- Did petitioner feign ignorance of respondent’s ownership?
- Awards and execution
- Was the award of attorney’s fees justified?
- Was the implementation of the writ of execution on December 15, 1997 valid?
- Should respondent or the sheriffs be held in contempt for executing the writ?
- Procedural questions
- Did the RTC have jurisdiction to issue a writ enforcing the CA decision when the case began in the MTCC?
- Was the July 4, 2000 RTC order directing issuance of a writ to enforce the CA decision proper?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)