Case Digest (G.R. No. 212034) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Colegio Medico-Farmaceutico de Filipinas, Inc. v. Lily Lim, petitioner Colegio Medico-Farmaceutico de Filipinas, Inc., the registered owner of a building in Sampaloc, Manila, filed on June 19, 2008 before the Metropolitan Trial Court (MeTC) a Complaint for Ejectment with Damages against respondent Lily Lim, President/Officer-in-Charge of St. John Berchman School of Manila Foundation. Petitioner alleged that it had leased the premises to respondent initially under a one-year contract from June 2005 to May 2006 and had offered a renewal for June 2006 to May 2007, which respondent did not return. After a December 2007 board decision not to renew, petitioner’s president, Dr. Virgilio C. Del Castillo, on March 5, 2008 sent a demand letter for unpaid rentals and utilities totalling ₱604,936.35 and requested respondent to vacate by March 16, 2008; respondent refused. Respondent countered that she had acquired rights under an original ten-year lease from 2003 to 2013, that the one-ye Case Digest (G.R. No. 212034) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Lease and Demand
- Petitioner Colegio Medico-Farmacéutico de Filipinas, Inc. (owner) leased its Sampaloc, Manila property to respondent Lily Lim (President/OIC of St. John) for June 2005–May 2006; attempted renewal for June 2006–May 2007 was not returned.
- In December 2007, the Board resolved not to renew; on March 5, 2008, President Del Castillo sent a demand letter for ₱604,936.35 and vacatur by March 16, 2008; respondent refused.
- Respondent’s Position
- Original 10-year lease (June 2003–May 2013) was made with St. John and assigned to respondent in May 2005 with petitioner’s approval; the 2005–2006 one-year contract did not intend to shorten the original term.
- Respondent remained in possession post-2006 with petitioner’s acquiescence, sought property repairs, and suspended rent payments due to unaddressed repair requests.
- Procedural History
- MeTC (June 1, 2009): Dismissed complaint for lack of valid demand letter authority.
- RTC (May 13, 2010): Reversed MeTC, held demand letter valid (ratified by May 13, 2008 Board resolution), ordered ejectment, damages, attorney’s fees.
- CA (June 13, 2013 Decision; April 7, 2014 Resolution): Reversed RTC, dismissed complaint for failure to attach Board resolution; denied reconsideration.
- SC: Petition for Review on Certiorari under Rule 45 filed by petitioner.
Issues:
- Procedural and Jurisdictional
- Is failure to attach the Board resolution authorizing the President a fatal defect in the complaint (verification and certification)?
- Can the President validly issue the demand letter without prior Board authorization?
- Merits of Unlawful Detainer
- Are the essential requisites of unlawful detainer satisfied?
- What is the proper amount of reasonable compensation and interest/damages?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)