Title
Mesina vs. Court of Appeals
Case
G.R. No. 100228
Decision Date
Jul 13, 1994
The Supreme Court affirms the Court of Appeals' decision, ruling that there is no identity of parties or causes of action and upholding the retroactive application of the Rental Law.
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Case Digest (G.R. No. 100228)

Facts:

  • Property located in Quiapo, Manila was originally leased by Clemente de Jesus in the late 1800s.
  • Clemente bought two houses on the property in 1921.
  • After Clemente's death in 1972, Paz and Peter de Jesus, his successors-in-interest, continued to live on the property.
  • Peter resided in one of the houses while the other house was leased to tenants.
  • The property was sold to Susana Realty, Inc., and eventually to Cetus Development Corporation (CETUS) in 1984.
  • CETUS filed a complaint for ejectment against Paz in 1986, alleging that she sublet the premises without written consent.
  • Metropolitan Trial Court dismissed the complaint, ruling that Paz occupied the property as the successor-in-interest of the registered lessee.
  • In 1989, CETUS initiated another ejectment proceeding, this time impleading both Paz and Peter as defendants.
  • Metropolitan Trial Court ordered Paz and Peter to vacate the premises, but the Regional Trial Court reversed the decision.
  • Court of Appeals reversed the decision of the Regional Trial Court.

Issue:

  • (Unlock)

Ruling:

  • Supreme Court dismissed the petition and affirmed the decision of the Court of Appeals.
  • No identity of parties between the first case and the present case with respect to Peter de Jesus.
  • Peter was never impleaded in the first court proceedings, so he cannot be bound by the pronouncements of the court in the first case.
  • No identity of causes of action between the two cases.
  • First case based on the demand letter to vacate for subleasing the leased premises without consent.
  • Present case involves the alleged viola...(Unlock)

Ratio:

  • Requisites for res...continue reading

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