Case Digest (G.R. No. 184698)
Facts:
Spouses Alberto and Susan Castro v. Amparo Palenzuela, et al., G.R. No. 184698, January 21, 2013, Supreme Court Second Division, Del Castillo, J., writing for the Court. Respondents (lessors) owned several fishponds in Bulacan which they leased to petitioners Spouses Alberto and Susan Castro for five years (March 1, 1994–June 30, 1999) under a written Contract of Lease stipulating a total consideration, staged annual payments by postdated checks, an obligation to assume certain arrears, prohibition on subleasing, lessee responsibilities for repairs/licenses, and a P1,000,000 liquidated damages clause plus 25% attorneys’ fees if suit were necessary.The lease expired June 30, 1999, but petitioners remained on the premises until August 11, 1999 (41 days). On July 22, 1999 respondents sent petitioners a handwritten demand letter stating petitioners owed P378,451.00 (breakdown: unpaid balance P111,082.00; interest P23,344.00; trespassing fee for July 1999 P244,025.00). Petitioners received the letter.
Respondents filed Civil Case No. Q-00-41011 in the Regional Trial Court (Quezon City, Branch 215; later re-raffled to Branch 85) on June 8, 2000, claiming unpaid rents, damages for extended stay, and P2,000,000.00 for restoring damaged warehouses, plus moral/exemplary damages and attorneys’ fees. Petitioners defaulted for failure to answer; respondents presented evidence including a statement of account and testimony that petitioners owed P863,796.00. The trial court later lifted default, but petitioners repeatedly failed to participate fully; the trial court ultimately struck petitioner Alberto Castro’s testimony and considered the case submitted.
On January 31, 2005 the RTC (Branch 85) rendered judgment ordering petitioners jointly and severally to pay P863,796.00 as actual/compensatory damages, P50,000.00 moral, P50,000.00 exemplary, 25% attorneys’ fees, and costs, but reduced damages for warehouse loss to nominal (respondents failed to prove amount). Both sides moved for reconsideration; the trial court denied them. Petitioners appealed.
The Court of Appeals (CA) in a January 29, 2008 Decision (CA-G.R. CV No. 86925) affirmed the RTC judgment in toto, finding petitioners failed to controvert evidence of unpaid rents, bounced postdated checks, subleasing, and overstay; it sustained moral/exemplary damages and the 25% stipulated attorneys’ fees under Article 2208, and denied petitioners’ motion for reconsideration on September 15, 2008. Petitioners filed a Petition for Review on Certiorari to the Supreme Court challenging (A) denial of a hearing on their motion for reconsideration (Rule 37, Sec. 1), (B) the fa...(Subscriber-Only)
Issues:
- Did the trial court abuse its discretion in refusing to hear petitioners’ Verified Motion for Reconsideration under Section 1, Rule 37?
- Whether respondents proved liability for unpaid rents in the amount awarded by the trial court and CA, or whether the July 22, 1999 demand letter fixed petitioners’ admitted liability at a lesser amount?
- Whether moral and exemplary damages and attorneys’ fees w...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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