Title
Quevada vs. Court of Appeals
Case
G.R. No. 140798
Decision Date
Sep 19, 2006
A lessor sued a tenant for unlawful detainer after lease expiration; tenant claimed implied trust and reimbursement for house improvements. Courts ruled for lessor, allowing reimbursement for improvements but rejecting implied trust.

Case Digest (G.R. No. 140798)
Expanded Legal Reasoning Model

Facts:

  • Parties and Contractual Relationship
    • Marcelito D. Quevada (petitioner) is the lessee of a portion of a residential house situated on a parcel of land in Sampaloc, Manila.
    • Juanito N. Villaverde (private respondent) is the lessor and owner of the lot and residential house.
    • In 1994, both parties entered into a lease contract for a portion (96 square meters) of the residential house for one year (August 15, 1994 to August 15, 1995) at P2,500 monthly rent.
    • They executed an extension of this lease from August 15, 1995 to April 15, 1996.
    • After the lease's expiration, Quevada continued to possess the premises without paying rent.
  • Demand for Vacation and Subsequent Proceedings
    • Villaverde made several demands to vacate the premises which Quevada refused without justifiable reason.
    • The parties went to the barangay court for conciliation; Quevada repudiated an agreement to vacate on December 31, 1997.
    • On January 20, 1998, Villaverde served a written notice to vacate within fifteen (15) days and to pay P5,000 monthly rental starting May 1996 until vacation.
  • Petitioner’s Position and Contentions
    • Quevada alleged that he started constructing the house on the lot in November 1985, finishing in 1986, occupying it as his residence thereafter.
    • He claimed to have intended to buy the lot but failed to raise the P1,000,000 purchase price. Villaverde assured he would transfer the title once Quevada could pay.
    • The lease contract was meant only as a temporary arrangement, involving rent payment for land only since the house belonged to Quevada.
    • Villaverde allegedly refused rental payments, leading Quevada to open a trust account for the monthly payments.
    • Quevada asserted an implied trust in his favor, making him the beneficial owner of the lot.
  • Lower Courts' Decisions
    • The Metropolitan Trial Court (MeTC) ruled in favor of private respondent Villaverde, ordering Quevada to vacate, pay reasonable compensation of P2,500 monthly from May 1996, and allowed him to remove improvements on the premises.
    • The Regional Trial Court (RTC) affirmed the MeTC decision without reversible error.
    • The Court of Appeals (CA) likewise affirmed the RTC decision and denied Quevada’s motion for reconsideration.
  • Issues Raised in the Petition for Review
    • Whether an implied trust was created in favor of Quevada making him beneficial owner entitled to possession.
    • Whether Quevada should be reimbursed for the value of the house improvements.
    • Whether MeTC had jurisdiction, considering the unlawful withholding occurred more than one year before the ejectment suit filing.
    • Whether Villaverde, not the titled owner, could bring the ejectment action.

Issues:

  • Is the action for ejectment proper under the circumstances?
  • Can the lessor, who is not the titled owner of the property, bring an action for ejectment (unlawful detainer)?
  • Is Quevada entitled to reimbursement for the value of the house built on the leased property?
  • Was there an implied trust created in favor of Quevada with respect to ownership of the land?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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