G.R. No. 15697 - People vs Singson

Spouses Virgilio and Josie Jimenez entered into a sublease arrangement in 1980 with Purisima Salazar, who had leased a lot and building at 2853 Juan Luna Street, Tondo, Manila from respondent Patricia, Inc. since 1970.
In 1995, Purisima Salazar abandoned the property, accumulating back rentals dating from January 1992, which led to the termination of her lease with Patricia, Inc.

On March 29, 1995, Patricia, Inc. sent a letter to the Jimenez spouses, notifying them of the termination of Purisima Salazar’s lease and demanding that they vacate the premises within fifteen days.
Despite the notice, the Jimenez spouses refused to leave the property.

On May 5, 1995, Patricia, Inc. filed a complaint for unlawful detainer against the Jimenez spouses, alleging that they continued to occupy the property without a valid lease contract, relying solely on the prior sublease which had effectively ended with the termination of Salazar’s lease.
The complaint detailed how the Jimenez spouses entered the property as sublessees and continued their occupancy by mere tolerance of the owner after the termination of the original lease.

The Metropolitan Trial Court (MeTC) ruled in favor of Patricia, Inc., ordering the Jimenez spouses to vacate the premises, pay a monthly rental of ₱3,000.00 from April 1995 until vacatur, and compensate for attorney’s fees and costs.
The Jimenez spouses appealed the MeTC decision to the Regional Trial Court (RTC), which modified the decision in their favor by implying a new lease contract based on their continued payment of rentals, extending the lease for one year and ordering reimbursement for the construction of a house on the property.
Subsequently, both parties filed separate petitions for review with the Court of Appeals, which were consolidated. The appellate court dismissed the Jimenez spouses’ petition, upheld the MeTC ruling, and emphasized that their continued occupancy was by tolerance without a valid lease contract.

The Jimenez spouses later contested the jurisdiction of the MeTC, arguing that the proper venue was the RTC since the complaint should have been construed as an action for forcible entry or unlawful detainer requiring a technical designation.
The Court of Appeals rejected the timely raising of the jurisdictional issue by the petitioners, noting their prior participation in the lower court proceedings, and reaffirmed the jurisdiction of the MeTC over the subject matter.

Whether the Metropolitan Trial Court had proper jurisdiction over the unlawful detainer action despite petitioners’ assertion that the complaint, by not alleging specific details regarding the sublease nature or their entry, should have shifted the case into an accion publiciana (reinvindicatory action) proper for the RTC.
Whether the petitioners’ late and inconsistent challenge to the jurisdiction of the MeTC is barred by laches given their earlier participation in the proceedings before that court.

Whether the sublease entered into by the Jimenez spouses, which was during Purisima Salazar’s lease period with Patricia, Inc., remains valid after the termination of the principal lease between Salazar and Patricia, Inc.
Whether their continued occupancy—even though initially with the owner’s tolerance—can be equated to an implied renewal or a new lease contract.

Whether the Jimenez spouses are entitled to full reimbursement for the house they constructed on the property after the building was gutted by fire in 1987.
Or whether, pursuant to Art. 1678 of the Civil Code, they are limited to recovering only one-half of the value of the improvements, subject to the lessor’s election.

Whether the contention by petitioners that the property is registered in the name of the City of Manila and not in the name of Patricia, Inc. is a proper issue to raise in the context of the unlawful detainer action.
Whether such a title dispute, not raised in the lower court, may be considered on appeal.