G.R. No. 136253 - People vs. Lugod

Plaintiff and Appellee: Consuelo T. De Casas.
Defendant and Appellant: Teresita F. Peyer.
Subject Matter: Unlawful detainer action concerning the premises known as Lot No. 4-C-ID-3-M, subdivision plan Psd-21891, with an area of 3,716.1 square meters, located at 150 V. Mapa, Sta. Mesa, Manila.

Plaintiff’s claim is based on a contract of lease, annexed as “Annex A” to the complaint, alleged to have been entered in February 1951.
Defendant, in her answer, denied entering into the alleged contract; she maintained occupying the premises for about 30 years under a different arrangement.
The dispute included the issue of rent: the contract specified an annual rental adjusted to P1,475.83 plus real estate tax (P606.37) for 1956, whereas defendant claimed she had always paid a yearly rent of P700.00.

The case commenced on November 21, 1956, in the Municipal Court of Manila as an action for unlawful detainer, with plaintiff seeking possession of the premises and payment of rents due.
On December 28, 1956, the municipal court rendered judgment ordering the defendant to vacate the premises and to pay the total amount computed from arrears in rent and additional amounts for future rentals pending vacating of possession.
Defendant paid a partial amount (P2,082.20, representing arrears plus real estate tax and computed additional monthly rent) but subsequently appealed the judgment to the Court of First Instance.

The suit was not an ejectment suit under Rule 72 of the Rules of Court.
Claiming ownership of a house on the premises and disputing the increased rental amount as unjustified.
Arguing that her longstanding practice of paying P700.00 per annum should prevail.

Defendant also filed a counterclaim seeking attorney’s fees (P500) on the ground that the action was unwarranted and compelled litigation.
Plaintiff responded by relying on a prior judgment (Civil Case No. 18346 of the Court of First Instance) that had validated the contract of lease in question.

Plaintiff filed a motion for immediate execution of the judgment because the defendant neither paid nor deposited the rents due from January 1957.
On March 18, 1957, the court granted the motion for immediate execution and later issued a writ of execution on April 4, 1957.
Defendant subsequently deposited P1,500 and sought the suspension of the writ, but her efforts were met with additional orders:

A writ of demolition was pursued by plaintiff, particularly after defendant failed to show cause regarding a building she had constructed on the property.
Multiple motions for postponement were filed by the defendant, including one citing illness, however, these were either postponed or denied by the court.

After numerous postponements and missed hearings (notably on December 3, 1957, January 16, 1958, and March 13, 1958), the lower court rendered judgment on May 29, 1958.

Defendant-appellant, on appeal, contended that the lower court abused its discretion by:

Denying her motion for postponement, which she argued deprived her right to present her evidence due to alleged illness.
Denying her motion to suspend the proceedings under Republic Act No. 1162 as amended by Republic Act No. 1599, claiming that such statute covered the property in dispute.

The Court of Appeals forwarded the case to the Supreme Court on the ground that the errors raised pertained solely to questions of law.

Whether the lower court abused its discretion in denying defendant-appellant’s motion for postponement, especially given her allegation of illness and the consequent inability to present her evidence.

Whether the lower court erred in denying the motion to suspend proceedings based on Republic Act No. 1162 (as amended by Republic Act No. 1599), specifically regarding the characterization of the property as an hacienda or part of one.

Whether defendant-appellant’s sole defense of willingness to pay a “reasonable” rental, rather than the increased rent claimed by the plaintiff-appellee, constitutes a meritorious defense sufficient to warrant postponement or suspension of the execution proceedings.