Case Digest (G.R. No. 176341)
Facts:
The case caption is Pro-Guard Security Services Corporation v. Tormil Realty and Development Corporation, G.R. No. 176341, July 07, 2014, the Supreme Court Second Division, Del Castillo, J., writing for the Court.Petitioner Pro-Guard Security Services Corporation (Pro-Guard) occupied Unit M, 3rd Floor, Torres Building. Respondent Tormil Realty and Development Corporation (Tormil) claimed ownership of the land and improvements where Torres Building stands. The ownership dispute began with a Deed of Assignment dated July 24, 1984 by Manuel A. Torres, Jr. (Manuel) purporting to assign three parcels and improvements to Tormil; the titles, however, remained in Manuel’s name and he later revoked the assignment. Manuel and others later organized Torres Pabalan Realty, Inc. (Torres‑Pabalan), to which Manuel assigned the same parcels as capital; the Torres Building was completed in 1985 and units were thereafter rented out, with Edgardo Pabalan (Edgardo) acting as building administrator and occupying the 2nd floor.
Tormil filed an action with the Securities and Exchange Commission (SEC) in March 1987 (SEC Case No. 3153) to compel Manuel to turn over documents needed to transfer titles; the SEC ruled for Tormil (March 6, 1991), which ruling was affirmed by the SEC en banc, and that judgment was later sustained on appeal such that it became final and executory on December 12, 1997. Meanwhile, in March 1994 Pro-Guard entered into an agreement with Edgardo for occupancy of a 3rd‑floor unit in exchange for security services rendered to Torres‑Pabalan. By October 1998 the titles and tax declarations had been registered in Tormil’s name.
On November 5, 1998, Tormil wrote to Edgardo, Atty. Augustus Azura (occupant of a 2nd‑floor law office), and Pro-Guard, asking them to validate possession/enter into a lease with Tormil and settle past rents; after no compliance Tormil on November 16, 1998 sent separate demands to vacate and to pay P20,000.00 monthly rental from the time of occupation until turnover. When the demands were ignored, Tormil filed separate ejectment (unlawful detainer) suits in the Pasay City Metropolitan Trial Court (MeTC) against Edgardo and Augustus (Civil Case No. 2324‑98) and against Pro‑Guard (Civil Case No. 2334‑98), later consolidated.
The MeTC (Branch 44) found for Tormil and, in a June 28, 1999 Decision, ordered among other things that Pro‑Guard vacate and pay fair and reasonable rental of P20,000.00 per month with legal interest "from June, 1995 until the premises is fully vacated." Pro‑Guard reported it had vacated on March 20, 1999. The Regional Trial Court (RTC), Branch 109, affirmed the MeTC Decision in a December 15, 1999 Decision. The Court of Appeals (CA), in CA‑G.R. SP No. 5...(Pro-only)
Issues:
- Whether the Court of Appeals erred in affirming the lower courts’ award of monthly rentals of P20,000.00 reckoned from the time Pro‑Guard began occupying the premises rather than from the date of demand...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)