G.R. No. 192383 - Dela Cruz vs. Dela Cruz

Forty-four consolidated ejectment cases were filed by respondent Antonio Lim against various individual petitioners who occupied market stalls at 942-952 Carmen Planas Street, Tondo, Manila.
The petitioners were acting in their individual capacities as tenants and were also represented through other related parties, including the Samahan ng Mga Nangungupahan sa Azcarraga Textile Market, Inc.

Goodland Company, Inc. was the owner of the building, and the petitioners originally occupied their stalls pursuant to lease contracts with the owner.
As of December 31, 1977, those individual contracts had expired, evidenced by a sign on the market wall instructing occupants to vacate.
On February 10, 1978, Antonio Lim became the lessee of the entire building, obtaining his rights from Goodland Company, Inc.

On March 27, 1978, respondent Lim, through his counsel, personally delivered a letter (Exhibit “C”) to each petitioner that:

Extended an additional five-day period beyond an earlier ten-day notice for entering into a new lease contract;
Stated that failure to sign the new lease would result in a 10-day period to vacate upon payment of back rentals starting February 1, 1978.

Prior to this formal demand, there were attempts at negotiation and conferences involving the petitioners and some representatives (including Mrs. Remedios Samala, president of the Samahan), focusing on the revised rental rates.
A subsequent communication from the Samahan (Exhibit “E”) proposed categorizing the stalls and fixing rentals accordingly; however, this proposal was rejected by Lim, who maintained his demand based on the increased operating expenses for the market premises.

Exhibit “B” showed that the total monthly gross income from rentals was calculated at P43,092.00, with operating expenses amounting to P39,855.35, resulting in a net income of P3,236.85 per month.
The increased rental demanded by Lim was justified on the basis that it reflected his own contractual rental payments and the increased operating costs, even though the new rate represented an increase of up to 182% compared to previous rentals.
Evidence, including the testimony of Eva Gonzales, illustrated that despite the operational increase in costs, comparable stalls in nearby markets maintained similar rental rates.

Private respondents (the petitioners and associated parties) initially filed a petition for certiorari with the Court of First Instance seeking nullification of the City Court’s decision.
Following a series of court orders, including the denial of a motion for an extension to file a motion for reconsideration, Lim obtained an ex parte motion for enforcement issued on June 11, 1981.

The respondent trial court ultimately set aside earlier decisions, including orders to vacate, whereas the appellate court reinstated portions of the City Court’s initial decision.
Petitioners later raised multiple assignments of error addressing issues such as the sufficiency of the demand to vacate and the classification of the Samahan as an indispensable party.

Whether the demand letters delivered by respondent Lim met the requisites under Section 2, Rule 70 of the Revised Rules of Court.
Whether the alternative stipulation in the notice—offering a choice between paying the increased rentals or vacating the premises—constituted a definite demand to vacate as required in unlawful detainer or ejectment cases.

Whether the petitioners, as individual stallholders, were the real parties in interest in the ejectment action.
Whether the Samahan ng Mga Nangungupahan sa Azcarraga Textile Market, Inc. was an indispensable party to the case, given its limited contractual role as an agent responsible for the collection and remittance of rentals.

Whether the City Court acquired jurisdiction over the ejectment cases despite the alleged absence of a specific demand to vacate under the traditional requirements.
Whether seeking certiorari was the appropriate remedy in light of the purported jurisdictional errors committed by the City Court.