G.R. No. 199689 - People vs. Constantino, Jr. y Binayug

In 1938, the Government acquired the Tala Estate (808 hectares) in Kalookan for the establishment of a leprosarium, although only one-fifth of the area was actually utilized for that purpose.
Under Republic Act No. 4085, the strict segregation of hansenites became unnecessary, prompting the State to consider a reduced allocation for the leprosarium.
To meet rising demands for low-cost housing and to create new residential areas within Metropolitan Manila, the State opted to reallocate portions of the property.

On April 26, 1971, President Ferdinand E. Marcos issued Proclamation No. 843, which allocated parts of the Tala Estate to various government agencies including the Department of Health, the National Housing Corporation, the PHHC, and the Department of Social Welfare and Development.
A joint PHHC-Bureau of Lands team was tasked with conducting the necessary survey and making inquiries regarding private rights in the estate; meanwhile, no title transfers were permitted until a definitive survey had been completed.

Faustino Acosta took possession of a vacant portion of the Tala Estate and constructed a house at No. 786, Barrio San Roque, Barangay 187, Tala, Caloocan City.
In August 1982, while serving as a Barangay Councilman, Faustino executed a deed titled “Registration of Property” over another 150-square-meter portion located west of the Barangay Hall, complete with constructed boundaries and physical improvements (fencing and vegetable planting).

In 1984, Paulino Calanday unlawfully took over the property by constructing an edifice (used as a beerhouse) without Faustino’s consent, which led to criminal complaints against Faustino that were later dismissed by the Metropolitan Trial Court (MTC) for non-compliance with PD 1508.
Paulino Calanday subsequently conveyed the beerhouse to Juanita Roces. An oral lease agreement was then established whereby Faustino permitted Juanita to use the property for a monthly rental of P60.00.
About a year later, Juanita Roces stopped paying the rent and transferred the lease to her nephew, Charles Limbauan, who thereafter assumed the lease and began paying P60.00 per month.

In February 1995, Congress enacted Republic Act No. 7999, converting 120 hectares of the Tala Estate into a housing site for the Department of Health’s residents and qualified employees.
Following the enactment of RA 7999, Faustino initiated legal action by filing a complaint for ejectment against Charles for non-payment of monthly rentals, having previously issued a demand letter on January 2, 1996, which originally provided a five-day period for compliance.
After Charles ignored the initial demand letter, Faustino intensified his efforts by sending a second demand letter on March 7, 1996, this time granting a fifteen-day period to vacate the premises, which Charles again refused to honor.

On February 7, 1996, Faustino filed an unlawful detainer complaint with the Metropolitan Trial Court (Civil Case No. 22521) seeking:

The MTC rendered a decision on December 29, 1997, in favor of Faustino, ordering Charles and his successors to vacate the specifically described commercial lot and to pay the agreed monthly rental with interest plus additional costs.
Charles appealed the decision to the Regional Trial Court (RTC), which affirmed the MTC decision on August 28, 1998.
Pursuant to the affirmed decisions, Charles (as petitioner) filed a Petition for Review on Certiorari before the Supreme Court challenging:

The proper application of the demand requirements under Section 2, Rule 70 of the Revised Rules of Court.
The suitability of leasing government property.
The validity of the amendment of pleadings to cure any alleged jurisdictional defect.
The effect of the death of Faustino Acosta (on October 22, 2000) on the case’s continuation and its alleged mootness.

Whether the demand letter(s) issued by the respondent met the procedural requirement under Section 2, Rule 70 for unlawful detainer cases, particularly given that the initial demand provided only a five-day period instead of fifteen for a parcel of land.
Whether the subsequent issuance of a second demand letter, grant of a fifteen-day period, and the timeline for filing the complaint effectively complied with the rule.

Whether the Metropolitan Trial Court properly acquired jurisdiction over the case given the alleged jurisdictional defect in the original complaint.
Whether the amendment of the complaint under Section 2, Rule 10 to cure any jurisdictional issues was a valid exercise of the court’s discretion.

Whether there existed a legally recognized lessor–lessee relationship between Faustino Acosta and Charles Limbauan that would justify the collection of monthly rentals.
Whether the factual findings on this matter, which were affirmed by the lower courts, should be re-evaluated by the Supreme Court.

Whether the death of the respondent (Faustino Acosta) rendered the case moot and academic.
Whether the failure of counsel to notify the court about the death and secure proper substitution of parties affected the validity of the proceedings.