G.R. No. 1561 - Enriquez vs. A.S. Watson and Co.

The plaintiff, Rafael Enriquez, acting as administrator of the estate of Antonio Enriquez, initiated the action to eject the defendants, A. S. Watson & Co. et al., from premises in Manila.
The defendants were alleged to be illegally occupying the property despite being in possession pursuant to a lease agreement.

On December 13, 1901, the plaintiff filed the action in the court of a justice of the peace in Manila seeking ejectment based on nonpayment of rent.
The initial judgment in that court favored the defendants.
The plaintiff then appealed the judgment and, on April 30, 1903, the Court of First Instance in Manila ruled in his favor by ejecting Watson & Co. and awarding damages amounting to 2,9200 pesos for nonpayment after November 1, 1901.

On January 25, 1901, Watson & Co. and Francisco Enriquez, then executor of Antonio Enriquez’s estate, entered into a lease agreement for property situated on the Escolta in Manila with a term of twelve years at a monthly rent of 1,200 pesos.
A previous decision (Rafael Enriquez vs. A. S. Watson et al.) confirmed that the lease was valid for six years despite the stipulated term.
The lease contained a clause specifying that “The rent shall be paid monthly in advance in the first days of each month…” with detailed instructions for payment allocations.

Under the lease, the monthly rent was to be paid in advance.
For the month of November 1901, Watson & Co. did not pay the rent by the deadline stipulated in the contract.
Although the defendants later deposited the rents for November and December in court on December 13, 1901, the timing of this deposit raised the question of whether a sufficient period for cure had been provided.

Watson & Co. argued that the action was prematurely commenced, asserting that no formal demand for the overdue rent had been made on or after the appropriate due date.
They contended that the term “in the first days” of the month should allow payment up to the fifteenth day, thereby delaying the point at which nonpayment could constitute a default.
The appellants claimed that thirty days had not lapsed after any such demand (if any had been made) before the commencement of the action.

Plaintiff’s supplementary argument provided an interpretation by dividing the month into three equal parts labeled “the beginning, the middle, and the end.”
Based on this reasoning, the Court adopted the interpretation that “in the first days” means from the first to the tenth day of the month.
Consequently, Watson & Co. had the entire tenth day to remit the rent, and no demand was made after the tenth day of November, leaving the defendants without the benefit of a full thirty-day period to pay the overdue rent.

The case was analyzed in light of the rule laid down in Francisco Saez Co-Tiongco vs. Co Quing Co, which addressed the timing of demands and commencement of actions in similar circumstances.
Also, the issue of jurisdiction upon an appeal from the justice of the peace to the Court of First Instance was touched upon, referencing the decision in Alonso in Municipality of Placer.

Whether the contractual term “in the first days” of the month should reasonably be interpreted as giving Watson & Co. until the fifteenth day, or if it connotes a period from the 1st to the 10th day for payment.
Whether the action for forcible entry and detainer was prematurely commenced by the plaintiff, given that no formal demand for the overdue November rent was made on or after the tenth day, thus depriving the defendants of the statutory thirty-day period to cure the default.
Whether the jurisdictional transformation upon appeal (from the justice of the peace to the Court of First Instance) affects the determination of whether due process regarding the payment demand was observed.