Case Digest (G.R. No. 166875)
Facts:
Digna Consumido v. Hon. Reynaldo G. Ros, et al., G.R. No. 166875, July 31, 2007, Second Division, Tinga, J., writing for the Court.Petitioner Digna Consumido was sued in an ejectment action filed by spouses Ramon Saura, Jr. and Fatima Saura (respondents) before the Metropolitan Trial Court (MeTC) of Manila, docketed as Civil Case No. 170458. The Sauras alleged that in 1995 they entered into two lease contracts with Consumido covering Units 982 and 980 on A.H. Lacson Street, Sampaloc, Manila, with monthly rents of P6,400 and P6,000 respectively, and that Consumido defaulted beginning in late 1996 and August 1997, prompting demands and eventual filing of the ejectment suit seeking possession, unpaid rentals (claimed at P615,000) and attorney’s fees.
In her answer, Consumido asserted that she actually contracted with the late Ramon Saura, Sr., who organized Villa Governor Forbes Corporation (VGFC) as administrator/lessor, and that she paid rents to the Saura family until June 1999. She later learned that Sandalwood Real Estate Development Corporation (SREDC) had acquired title to the premises in April 1995 and negotiated occupancy with SREDC; she claimed this provided a just ground for not complying with respondents’ demands.
After summary proceedings, the MeTC, in a decision dated 19 April 2002, dismissed the ejectment suit, finding that ownership was the subject of a separate pending litigation, that SREDC as successor-in-interest had earlier brought and lost an ejectment suit, and that respondents acted merely as administrators/representatives of VGFC and were not the real parties in interest. The Regional Trial Court (RTC), Branch 33 of Manila, reversed by decision dated 17 September 2002, finding respondents entitled to material possession because Consumido had continued to remit rentals to them after the death of Ramon Saura, Sr., and ordering ejectment, payment of arrears (Php714,800.00), attorney’s fees and costs. The Court of Appeals (CA), in CA-G.R. SP No. 75285, rendered a decision dated 13 September 2004 affirming the RTC and denied a motion for reconsideration in a Resolution dated 24 January 2005.
Consumido filed a Ru...(Subscriber-Only)
Issues:
- Were respondents the real parties in interest with locus standi to maintain the ejectment suit?
- Was petitioner estopped from denying that respondents were her landlords by virtue of her payment of rent...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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