G.R. No. 223785 - Lajave Agricultural Management and Development Enterprises, Inc. vs. Spouses Javellana

LAJAVE AGRICULTURAL MANAGEMENT AND DEVELOPMENT ENTERPRISES, INC. was the lessee of agricultural portions of a titled property in Silay City, Negros Occidental, and additional inherited shares in Barangay Matab-ang, Talisay City, Negros Occidental.
Spouses Agustin Javellana and Florence Apilis-Javellana were the lessors/landowners; Agustin acquired ownership from his father, the late Justice Luis Javellana, by Deed of Absolute Sale dated July 7, 1987 and by intestate succession upon the latter's death on August 25, 1993.
The primary Silay City parcel was covered by Transfer Certificate of Title No. T-7203; the Talisay lands were covered by Transfer Certificate of Title No. T-142126.

On May 13, 1998, LAJAVE and Agustin executed a Contract of Lease for Agustin’s seven-hectare portion in Hacienda San Isidro, Silay City, for ten years covering crop years 1988-1989 to 1997-1998.
The lease provided for annual rental of thirteen piculs of sugar per hectare and contained a stipulation that, upon expiration or any extension, LAJAVE would peaceably and voluntarily surrender the land without demand.

After the death of the lessor’s father and beyond the contractual period, LAJAVE continued to occupy the Silay property and expanded operations to include other inherited shares in Talisay without executing new lease contracts for those areas.
LAJAVE paid annual compensation to Agustin but Agustin alleged lack of transparency on computation and frequent delays.
Agustin claimed that from January 22, 2003 to June 25, 2010, LAJAVE paid PHP 928,928.27 in rentals for the Silay property, while he computed, using Sugar Regulatory Administration data, that correct rentals should have been PHP 1,253,423.15, yielding an alleged unpaid balance of PHP 324,494.88.

Agustin served a demand letter dated March 1, 2010 to vacate the Silay property; reiterated demand on March 5, 2012; and on March 5, 2012 demanded vacation of the Talisay property.
On March 26, 2012, Spouses Agustin and Florence Apilis-Javellana filed a Complaint for unlawful detainer in the Municipal Trial Court in Cities (MTCC), Silay City, docketed Civil Case No. 1149-C, concerning Hacienda San Isidro.
On July 16, 2012, Agustin filed another unlawful detainer Complaint in MTCC Talisay, Civil Case No. (12)-925, for Hacienda Sta. Maria, Talisay City.
Both unlawful detainer cases were dismissed by their respective MTCCs for lack of jurisdiction and/or lack of cause of action.

On September 24, 2012, Spouses Agustin and Florence Apilis-Javellana filed Civil Case No. 12-41648 in the Metropolitan Trial Court (MeTC) of Quezon City for collection of sum of money alleging deficiency in rentals for crop years 2000-2001 to 2008-2009.
On October 29, 2012, LAJAVE moved to dismiss on grounds of violation of the rule against splitting a single cause of action, *litis pendentia*, and forum shopping, asserting identity of parties, rights and reliefs with the unlawful detainer suits.
Agustin opposed on November 5, 2012, contending that the collection claim concerned damages sustained prior to any unlawful possession and thus was a separate cause of action not barred by *litis pendentia*.
On December 10, 2012, the MeTC, Quezon City, Branch 38, granted the motion to dismiss, ruling that the deficien...(Subscriber-Only)

Whether, during the pendency of unlawful detainer actions filed by Spouses Agustin and Florence Apilis-Javellana, an independent action for collection of sum of money seeking alleged rental deficiencies for periods prior to the declared unlawfulness of possession may be maintained without violating the rules on splitting a single cause of action, *litis pendentia*, and forum shopping.

Whether the damages asserted in the collection suit are identical to the damages recoverable in an unlawful detainer action.
Whether the deficiency in rentals for crop years 2000-2001 to 2008-2009 could have been...(Subscriber-Only)