Case Digest (G.R. No. 203697)
Case Digest (G.R. No. 203697)
Facts:
Analita P. Inocencio, Substituting for Ramon Inocencio (Deceased) v. Hospicio de San Jose, G.R. No. 201787, September 25, 2013, the Supreme Court Second Division, Carpio, J., writing for the Court.
The dispute arose from a lease dated 1 March 1946 whereby Hospicio de San Jose (HDSJ) leased a parcel in Pasay City to German Inocencio; the contract was renewed repeatedly, the last written renewal dated 31 May 1951 and containing Section 6 providing that the contract was "nontransferable unless prior consent of the lessor is obtained in writing." German built two buildings on the leased parcel in 1946, subleased portions, and designated his son Ramon Inocencio to administer the property. In 1990 HDSJ notified German of an increase in rentals. German died in 1997; Ramon did not notify HDSJ but continued collecting rents from sublessees and paying rent and taxes to HDSJ.
On 1 March 2001 HDSJ’s administrator informed Ramon that, because payments had been accepted after German’s death, an implied month-to-month lease existed and it would expire 31 March 2001; Ramon requested renegotiation on 12 March 2001. On 3 April 2001 HDSJ declared it would not renew the lease, alleging Ramon had subleased to about 20 families without consent, and thereafter refused to accept his rental tenders. HDSJ reiterated termination on 3 March 2005, demanded payment of alleged unrealized fruits, posted notices to sublessees to vacate, and contracted separately with new lessees in April–May 2005. Some sublessees then ceased paying rent to Ramon.
On 28 June 2005 HDSJ filed an unlawful detainer complaint in Metropolitan Trial Court (MeTC), Branch 48, Pasay, seeking eviction, reasonable compensation (P552,195.36), monthly rentals from April 2005, and attorneys’ fees. Ramon (later substituted by his wife Analita after his death) answered, asserting among others that the buildings on the land were German’s property (supported by building permits and tax declarations), that the lease’s Spanish text should be excluded if untranslated, that HDSJ was estopped, and that Article 1650 permitted subleasing absent express prohibition.
The MeTC (Decision 22 May 2008) ruled for HDSJ, ordered eviction, awarded P552,195.36 for use and occupation (plus P10,512 monthly from April 2005) with 12% interest and P50,000 attorneys’ fees. The Regional Trial Court (RTC), Branch 119, Pasay, dismissed Analita’s appeal on 21 January 2009, affirming that the lease’s intransferability clause barred Ramon from subleasing. Reconsideration was denied on 25 October 2010. The Court of Appeals (CA), in CA-G.R. SP No. 117009 (Decision 12 January 2012; Resolution 9 May 2012), affirmed the RTC but modified the compensatory award to P504,576.00 with 6% interest until finality, then 12% thereafter. Analita petitioned the Supreme Court seeking annulment of the CA decision.
Issues:
- Were the sublease contracts executed by Ramon valid?
- Did Hospicio de San Jose commit tortious interference with the contractual relations between Ramon and his sublessees?
- Did Ramon (through his estate) own the buildings erected on the leased premises as separate property permitting independent leases after termination of the land lease?
- Is HDSJ entitled to reasonable compensation and attorneys’ fees as awarded, and were the CA’s modifications appropriate?
- Was HDSJ’s action for unlawful detainer barred by prescription?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)