Case Digest (G.R. No. 170509)
Facts:
Viegely Samelo v. Manotok Services, Inc., G.R. No. 170509, June 27, 2012, Supreme Court Second Division, Brion, J., writing for the Court. Petitioner Viegely Samelo, through her attorney-in-fact Cristina Samelo, seeks review of the Court of Appeals' decision and resolution in CA-G.R. SP No. 85664.Respondent Manotok Services, Inc. alleged it administered Lot 9-A, Block 2913 (2882 Dagupan Extension, Tondo, Manila). On January 31, 1997 respondent and petitioner entered into a one-year lease for a portion described as Lot 4, Block 15, at P3,960 monthly. The lease expired on December 31, 1997, but petitioner remained in possession and stopped paying rent. On August 5, 1998 respondent (through its president Rosa Manotok) sent a demand to vacate and to pay compensation; petitioner refused.
On November 18, 1998 respondent filed an action for unlawful detainer with the Metropolitan Trial Court (MeTC), Branch 3, Manila (Civil Case No. 161588‑CV), praying for possession and compensation. In her MeTC answer petitioner alleged that the premises are PNR property, that respondent had no title or authority to lease, that her signature on the lease was obtained by misrepresentation, and that she had possessed the premises since 1944.
The MeTC, in a judgment dated March 28, 2002, ruled for respondent, ordering petitioner to vacate, to pay compensation for use and occupancy, attorneys’ fees and costs. Petitioner appealed to the Regional Trial Court (RTC), Branch 50, Manila. The RTC, in its decision of July 1, 2004, set aside the MeTC judgment and dismissed the unlawful detainer complaint, finding respondent failed to prove authority to administer the premises and concluding petitioner had acquired ownership by long possession since 1944.
Respondent appealed to the Court of Appeals (CA-G.R. SP No. 85664). The CA, in a decision dated June 21, 2005, reversed the RTC, reinstated the MeTC judgment and held that (1) the tenant is estopped from disputing the landlord’s title or better right of possession while in possession under the lease, and (2) the only issue in unlawful detainer is material possession (though ownership may be provisionally considered only insofar as it illuminates possession...(Subscriber-Only)
Issues:
- Is the petitioner estopped from denying the respondent’s title or better right of possession while she remained in possession under the lease?
- Did the petitioner acquire ownership of the premises by adverse possession from 1944?
- Are unpaid rentals subject to interest, and if so, at what r...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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