Title
Gallarde vs. Moran
Case
G.R. No. L-19572
Decision Date
Jul 30, 1965
The Supreme Court dismissed a landlord's ejectment and damages complaint against tenants for failing to establish a cause of action due to lack of a definitive demand to vacate.
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Case Digest (G.R. No. L-19572)

Facts:

  • Dionisio B. Gallarde is the plaintiff and appellant.
  • Cesar S. Moran and Liboria L. Moran are the defendants and appellees.
  • On June 2, 1961, Gallarde filed a complaint for ejectment and damages against the Morans in the Court of First Instance of Agusan.
  • In 1954, Gallarde allowed the Morans to occupy his urban land with a rental agreement.
  • The initial rent was P15.00, later reduced to P12.00, and then to P10.00.
  • Gallarde claimed the Morans were irregular in their payments.
  • In January 1960, Gallarde notified the Morans that rent would increase to P80.00 starting March 1960.
  • He stated that if they did not agree to the new rent, he would demand they vacate the property.
  • The Morans allegedly failed to pay rent for several months, leading Gallarde to seek ejectment and damages.
  • The Morans filed a motion to dismiss, arguing Gallarde did not establish a cause of action due to lack of prior demand to vacate.
  • The trial judge agreed with the Morans and dismissed the complaint, prompting Gallarde to appeal.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the trial court's order dismissing Gallarde's complaint for ejectment.
  • The court found that the complaint did not establish a cause of action...(Unlock)

Ratio:

  • The Supreme Court's decision was based on the interpretation of Section 2 of Rule 72, which requires a landlord to make a demand for payment or compliance before initiating ejectment.
  • The court noted that Gallarde's complaint lacked specific allegations of a proper demand to vacate.
  • The first demand was conditional and did not clearly indicate the Morans' refusal to accept the new rental terms....continue reading

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