G.R. No. 128568 - Spouses Alcaraz vs. Tangga-an

Respondents Pedro M. Tangga-an, Menas R. Tangga-an, Virginia III Yvette R. Tangga-an, Cecil T. Villaflor, Hermes R. Tangga-an, Venus R. Tangga-an, Jupiter R. Tangga-an, Yvonne T. Fri, and Vivien R. Tangga-an filed a complaint for unlawful detainer against petitioners Reynaldo Alcaraz and Esmeralda Alcaraz.
The complaint alleged that the late Virginia Tangga-an leased a residential house to the petitioners under a contract that excluded the land, which was owned by the National Housing Authority (NHA). The lease required the petitioners to pay a monthly rent of ₱4,000 for five years starting November 22, 1991.
Petitioners allegedly failed to pay rent since November 1993 and were in arrears of ₱48,000 as of October 1994. Despite demands, petitioners refused to vacate the property.
Respondents sought ejectment and repossession for their own use and benefit.

Petitioners argued that on July 23, 1993, ownership of the lot was transferred by NHA to Virgilio and Angelita D. Tangga-an (relatives and heirs of Virginia Tangga-an). Transfer Certificate of Title No. 125657 was issued to Virgilio.
They claimed this transfer included the house, effectively canceling the lease contract with respondents as respondents no longer had legal rights over the property. Petitioners paid rent to Virgilio and Angelita thereafter.

The court ruled in favor of respondents, ordering petitioners’ immediate eviction.
Findings included the petitioners’ violation of the lease contract for non-payment of rent, lack of evidence that the house belonged to Virgilio alone, and pending litigation regarding the ownership of the lot among the Tangga-ans.
The court did not pass judgment on conflicting ownership claims as it was outside the scope of an unlawful detainer case.

The RTC affirmed the MTC’s decision, emphasizing that petitioners failed to show any amendment of the lease contract or justification for payment to Virgilio instead of respondents.
Virgilio failed to prove ownership of the house, and petitioners violated the binding lease agreement expiring November 22, 1996.
The contractual obligation to pay rent was underscored by Article 1159 of the Civil Code.

The Court of Appeals affirmed the rulings of the lower courts.
It held respondents, as heirs of the late Virginia Tangga-an, had the right to institute ejectment under Article 487 of the Civil Code.
The claim of Virgilio to the lot was contested in a separate pending action and could not negate respondents’ ownership of the house or suspend the ejectment proceeding.
Ownership of the lot does not automatically transfer ownership of the building.

The lease covered the land and the improvements, including the building.
Virgilio, as a co-heir, had equal rights over the property and could not be excluded unilaterally.
The registration of the land and improvements in Virgilio’s name was indefeasible under the Torrens system and could not be collaterally questioned.

Whether the lease contract included ownership of the lot in addition to the house.
Whether the subsequent transfer of the lot’s ownership to Virgilio Tangga-an affected the validity of the lease contract or the obligation to pay rent to respondents.
Whether payment of rent to Virgilio Tangga-an discharged the petitioners from their obligation under the lease.
Whether the ejectment suit was proper despite ongoing litigation regarding the ownership of the lot.
Whether the lease could be unilaterally rescinded by the petitioners following the alleged change in ownership of the lot and house.