Case Digest (G.R. No. 224006)
Facts:
CJH Development Corporation v. Corazon D. Aniceto, G.R. No. 224006 and G.R. No. 224472, July 06, 2020, Supreme Court Third Division, Leonen, J., writing for the Court.Corazon D. Aniceto (lessee) operated El Rancho Cafe and Restaurant on Camp John Hay, Baguio City. She initially occupied a junkyard site and constructed the restaurant between October and December 2003. On December 1, 2003, Aniceto and Camp John Hay Development Corporation (CJH Development, lessor) executed a lease effective to November 30, 2004; the parties later entered a lease dated November 18, 2005 (to November 17, 2006), which was amended to extend to May 17, 2007. After that term lapsed, the parties continued on a month-to-month basis, with Aniceto paying rent through February 28, 2008.
The Lease contained (i) Article VI, Section 1, providing that permanent improvements by the lessee become the lessor's property upon termination (and that the lessee has no right to reimbursement), and (ii) Article X, Section 2, authorizing the lessor to enter, inventory, and remove the lessee's merchandise upon noncompliance, to store it in the lessor's bodega, charge storage fees, and dispose of unclaimed property after 30 days, with an express clause that the lessor and its agents “shall not incur civil and/or criminal liabilities whatsoever.” On January 30, 2008, CJH Development notified Aniceto to vacate by March 1, 2008 for land development; further extension requests by Aniceto were denied.
Aniceto sought injunctive relief in the Regional Trial Court (RTC), which issued a 72‑hour Temporary Restraining Order (March 4, 2008) and a status quo order (March 6, 2008) but ultimately denied a writ of preliminary injunction. While her motion for reconsideration was pending, El Rancho was demolished (April 29–May 1, 2008 / referenced as May 1, 2008). Aniceto filed a complaint for damages seeking P4,983,625.00 (including P2,137,625 for personal properties).
The RTC (Branch 61, Baguio City) in a December 11, 2013 Decision ruled for Aniceto: it declared the demolition contrary to law and public policy; struck down Section 2, Article X as without force and effect; found bad faith by CJH Development and its lawyers and awarded actual damages of P2,183,625.00 (value of personal properties), moral damages (P1,000,000), exemplary damages (P500,000), attorney’s fees (P200,000) and costs. The RTC treated the structures and landscape as lessor-owned (per the lease) and therefore excluded their value from the award to Aniceto.
On appeal the Court of Appeals (Special Eighth Division) reversed in a July 27, 2015 Decision (and denied reconsideration in a March 8, 2016 Resolution). The CA concluded the lease expired May 17, 2007 and that an implied month‑to‑month tenancy arose; because the status quo order had lapsed and preliminary injunction was denied, CJH Development validly repossessed and demolished the premises under the lease. The CA set aside the RTC's declaration and most damages but ordered CJH Development to pay P2,183,625.00 representing the value of personal properties taken during demolition, subject to deduction for any items still held and returned undamaged.
Both parties filed Rule 45 petitions for review on certiorari with this Court (CJH Dev: G.R. No. 224006; Aniceto: G.R. No. 224472), later consolidated. Aniceto attacked the lease provisions as violating due process and public policy, alleged forcible entry and unlawful detainer, ...(Pro-only)
Issues:
- May questions of fact be raised in a Rule 45 petition for review on certiorari?
- Are the challenged provisions of the Lease Contract valid — specifically (a) Article X, Section 2 (authorizing extrajudicial entry and repossession), (b) Article VI, Section 1 (vesting ownership of permanent improvements in the lessor without reimbursement), and (c) is the Lease a contract of adhesion that invalidates those stipulations?
- Is CJH Development liable for the value of Aniceto’s personal properties that were taken and stored (and allegedly later deteriorated)?
- Are CJH Development and its lawyers jointly and sever...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)