G.R. No. 126171 - People vs. Genita, Jr., y Cultura

Petitioner Rodil Enterprises, Inc. (RODIL) has been lessee of the Ides O’Racca Building (“O’RACCA”) since 1959 under a lease originally granted by the Republic of the Philippines pursuant to R.A. 477 (formerly alien property).
In 1972 the lease was renewed for 15 years; RODIL in 1980 subleased space to the Bondocs, Divisoria Footwear, Chua Huay Soon and other members of the Ides O’Racca Building Tenants Association, Inc. (“ASSOCIATION”).

B.P. 233 (1982) authorized sale of classified commercial alien properties; RODIL offered to purchase O’RACCA in January 1987; Republic deferred action pending appraisal.
In September 1987 Director Factora granted RODIL a five-year renewal (1 Sep 1987–31 Aug 1992), but Secretary De Jesus of DGSREPM disapproved it favoring the ASSOCIATION and ordered issuance of a temporary occupancy permit to the latter.

October 1987: RODIL filed for specific performance, damages and injunction; RTC granted preliminary injunction; CA affirmed and required deposit of rentals pendente lite.
May 1992: Land Management Bureau custodian and DENR Secretary Factoran approved a ten-year renewal contract (retroactive to 1 Sep 1987) and a supplemental rent‐adjustment agreement.

August 1987–November 1992: The specific performance case was dismissed; the ASSOCIATION appealed; the Office of the President nullified the 1992 renewals but respondents Alvarez’ letter‐appeal was denied.
1993–1994: RODIL sued respondents Bondoc, Bondoc-Esto, Divisoria Footwear and Chua for unlawful detainer; MeTC and RTC rendered decisions ordering their ejectment and payment of arrears; CA in 1996 (CA-G.R. No. 39919) and 1996–1997 (CA-G.R. Nos. 36381, 37243) annulled the 1992 renewals and dismissed the UD actions.

RODIL filed two Rule 45 petitions (G.R. Nos. 129609, 135537) to reverse CA decisions; the cases were consolidated and argued before the Supreme Court.

Are the May 18, 1992 renewal contract and May 25, 1992 supplemental contract valid and binding despite prior administrative actions and injunctions?
Was the September 23, 1987 “renewal” ever a binding contract without formal approval communicated to RODIL?

Does RODIL, as lessee under valid contracts, have the right to eject respondents who occupy by mere permit or acquiescence?
Must a plaintiff in unlawful detainer prove prior physical possession to maintain the action?

Did the Court of Appeals err in annulling the 1992 contracts and dismissing the unlawful detainer cases?
Did the CA improperly disregard the administrative and contractual history in reaching its decisions?

Should the ASSOCIATION’s malicious prosecution counterclaim have been dismissed for failure to meet Rule 17 requirements or on the merits?