Case Digest (G.R. No. 171707)
Facts:
Spouses Wilfredo and Angela Amoncio v. Aaron Go Benedicto, G.R. No. 171707, July 28, 2008, First Division, Corona, J., writing for the Court.Petitioners Wilfredo and Angela Amoncio (lessors) owned a 600 sq. m. lot in Quezon City. On July 15, 1997 they leased a 120 sq. m. portion to Ernesto Garcia. On August 20, 1997 they executed a written lease with respondent Aaron Go Benedicto covering 240 sq. m., specifying a five-year term (renewable annually up to five years), use for a construction supply business, and various payment terms including an advance/deposit arrangement and that improvements become the lessor’s property at lease expiration.
Garcia and respondent took possession in December 1997. In July 1999 Garcia pre-terminated his lease; respondent remained until June 8, 2000. Petitioners allege respondent stopped paying rent in December 1999, occupied Garcia’s portion after Garcia left, and built improvements on an additional 120 sq. m. not covered by either lease. Petitioners demanded payment of arrears and cessation of construction; respondent allegedly ignored them, and petitioners rescinded the lease on January 27, 2000.
On June 23, 2000 petitioners sued in the Regional Trial Court (RTC), Branch 82, Quezon City, for recovery of possession and for several categories of unpaid rent, and sought a preliminary injunction. Respondent denied the allegations and counterclaimed for P600,000 (cost of two buildings he said were assigned to petitioners), P300,000 (adjusted cost for two other improvements), and P10,000 attorney’s fees. After trial RTC Judge Severino B. De Castro found for respondent, dismissed petitioners’ complaint for lack of factual and legal basis, and awarded respondent P600,000, P300,000 and P10,000 attorney’s fees.
Petitioners appealed to the Court of Appeals (CA) in CA-G.R. CV No. 79341. The CA (Eighth Division, penned by Justice Portia Alino-Hormachuelos) affirmed the RTC, reasoning that petitioners failed to prove occupation of unleased portions, could not demand rent for the unexpired period after they demanded respondent vacate, and waived the parol evidence rule by failing to object to respondent’s testimony regarding an oral agreement to construct buildings. Petitioners’ motion for reconsideration in the CA was denied on February 22, 2006.
...(Pro-only)Issues:
- Did the Court err in declining to disturb the factual findings of the RTC and CA regarding petitioners’ acquiescence in the construction and the parties’ oral agreement?
- Could respondent’s extrinsic testimony regarding the parties’ separate oral agreement be received despite the written lease (i.e., did petitioners waive the protection of the parol evidence rule)?
- Are petitioners entitled to recover rental payments for the period after respondent ceased paying and for the unexpired lease term?
- Are petitioners liable to respondent for the ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)