G.R. No. 155553 - Reyes vs. Heirs of Daez

The case arose from an ejectment action filed on September 23, 1997, by Cecilia D. Daez on behalf of the heirs of the deceased Eudosia D. Daez.
The subject property is a lot with two apartment buildings located at 654 McArthur Highway, Bonifacio, Caloocan City, covered by Transfer Certificate of Title No. 21852 still registered in the name of the deceased.
The heirs claimed ownership of the property and sought to regain possession by ejecting the defendants who were occupants under a verbal month-to-month lease agreement.

Defendants, comprising multiple individuals (including Nimfa Mitre Reyes, Beatriz Feliciano, Dolores "Baby" Alvarez, Baby Javier, Fernando Frias, Remedios Maymiero, Romulo Marca, Salvador Nebres, Vivian Sazon, and Erlinda Coronado), were long-term tenants who entered into a verbal lease agreement with Eudosia Daez and subsequently continued occupying the apartment units.
The defendants maintained that they paid their monthly rentals faithfully and that their right to remain in possession was grounded on the Rent Control Law (B.P. 877) and its subsequent amendments (including Republic Act 7644).

Plaintiffs, concerned about the deteriorating condition of the buildings (constructed in the 1950s), had the City Engineer’s Office inspect the property in 1996, after which a Building Inspector issued a report on December 12, 1996, recommending immediate restructuring or general repairs to ensure safety.
On January 21, 1997, based on the recommendation and following a letter from the City Engineer’s Office to plaintiffs, a formal notice was sent to the defendants directing them to vacate the premises so that the necessary repairs could be undertaken.
Plaintiffs asserted that the continued occupancy of the premises by defendants posed dangers not only to the tenants but also to the public at large.

Defendants countered by alleging that the apartment units were in good, sound, and safe condition, attesting that they had conducted and even funded necessary repairs and maintenance over the years.
They argued that the damage noted by the City Engineer was superficial and merely represented ordinary wear and tear.
Defendants maintained that, since the lease agreements fell under the protection of the Rent Control Law, they were entitled to the continued enjoyment of the property, and any exterior repairs could be accomplished without ejecting them.
Moreover, they contended that the plaintiffs’ actions were motivated by ulterior motives and that the proper legal recourse would have been through other remedies such as an accion publiciana or accion reivindicatoria.

Court Proceedings from the Regional Trial Court (RTC) to the Court of Appeals (CA)

The Metropolitan Trial Court (MeTC) rendered a decision on September 30, 1999, in favor of the plaintiffs ordering ejectment, payment of monthly rental compensation, and reimbursement of litigation expenses.
On appeal, the RTC on September 28, 2001, affirmed the MeTC decision, finding that the defendants’ possession was based on a verbal lease contract, and that upon the death of Eudosia Daez, the heirs stepped into the contractual rights.
The Court of Appeals (CA) later affirmed the RTC decision on July 23, 2002, rejecting the arguments that the respondents’ evidence (notably, affidavits and an unverified Position Paper) was inadmissible, while also relying on the presumption that the Building Inspector had duly performed her official duty.
Petitioners subsequently filed a petition for review on certiorari under Rule 45, alleging grave abuse of discretion, a lack of evidentiary basis in the lower court rulings, and procedural errors regarding the submission of affidavits, but these issues were not found sufficient to reverse the decisions of the lower courts.

Whether the ejectment order against the defendants should stand given that the lease agreement was verbal and covered by the Rent Control Law, which inherently protects tenants’ rights.
Whether the lower courts erred by basing their decisions on evidence that included an unverified Position Paper and documents that were argued to be hearsay, thus failing to meet the requirements stipulated under the Revised Rules on Summary Procedure.

Whether the failure of the respondents to submit direct testimony or to verify their Position Paper, as required by Sec. 9 in relation to Sec. 3(B) of the Revised Rules on Summary Procedure, constituted reversible error.
Whether the alleged non-compliance with the rules on the submission of affidavits and evidence deprived petitioners of due process in adjudicating the issues concerning the ejectment order.

Whether the factual findings of the lower courts were based on substantial evidence, particularly in relation to the building’s condition and the necessity for the repairs ordered by the City Engineer.
Whether the presumption of regular and official performance of duty by the Building Inspector was appropriately given weight in reaching the ejectment decision.