G.R. No. 141324 - Spouses Junson vs. Spouses Martinez

Respondents, spouses Antonio and Benedicta Martinez, are the registered owners of several parcels of land along E. Jacinto Street, Sangandaan, Caloocan City.
Petitioners include spouses Emilio and Virginia Junson and petitioner Cirila Tan, who are lessees occupying portions of the property where they erected their respective houses.

On June 21, 1985, written agreements were executed between petitioner parties and respondent Benedicta Martinez, establishing a month-to-month lease.
The lease contracts provided that either party could terminate the agreement upon a three-month notice.
The agreements allowed petitioners to continue their occupancy in exchange for payment of monthly rentals.

In March 1988, petitioner Cirila Tan received notice from respondents to vacate the portion of land she occupied, with a three-month period given, rent-free.
Similarly, in May 1988, petitioner spouses Junson were notified to vacate.
Following the notices, respondents ceased collecting rental payments from the petitioners.

Despite the notices, petitioners did not vacate the premises; instead, they deposited their respective rental payments in a bank account under the name of respondent Benedicta Martinez.
On July 18, 1994, petitioners filed petitions for consignation with the Metropolitan Trial Court (MeTC) of Caloocan City, depositing the rentals with the court.
For their failure to vacate, respondents instituted unlawful detainer cases, and these actions were subsequently consolidated with the consignation cases.

On August 18, 1995, the MeTC, Branch 53, rendered a decision dismissing the consignation petitions and ordering ejectment of petitioners from the property.
The ejectment order required petitioners to vacate the lot and ordered payment of reasonable compensation for unauthorized use, computed at P100.00 per month, plus attorney’s fees of P5,000.00.
The Regional Trial Court (RTC) affirmed the MeTC decision in toto, including the finding that the lease contracts had terminated as of May 1988.
Petitioners appealed to the Court of Appeals, challenging:

The finding that the lease contracts ended in May 1988, inconsistent with a continuing tolerant occupancy;
The assertion that respondents had withdrawn their tolerance via letters dated July 26, 1994;
The validity of respondents’ certification to file action and compliance with the prescribed barangay lupon conciliation procedure;
The orders requiring petitioners to vacate and to pay attorney’s fees.

The Court of Appeals denied the petition and affirmed the trial court’s decision. Petitioners’ motion for reconsideration was likewise dismissed.

The Supreme Court noted that the appellate review is confined to errors of law and that the factual findings of the trial and appellate courts are binding.
It was reiterated that a month-to-month lease, upon proper notice, terminates with the expiry of its period, thereby justifying ejectment under the relevant legal provisions.

Whether the trial court erred in determining that the month-to-month lease contracts terminated as of March and May 1988 upon proper notice.

The issue centers on whether the termination transformed the petitioners’ occupancy into one of mere tolerance.

Whether respondents effectively withdrew their tolerance to permit ejectment through the issuance of written notices.

Specifically, if the letters dated July 26, 1994, constituted a proper withdrawal of permission.

Whether the certification to file action by respondents was valid and if their filed complaints complied with the requirements of the barangay lupon conciliation procedure.

This includes the question of whether non-compliance with PD 1508's conciliation process could be used to challenge the court’s jurisdiction.

Whether the RTC erred in ordering petitioners to vacate the property and in awarding attorney’s fees.

The appropriateness and reasonableness of the P5,000.00 attorney’s fees were also called into question.

Whether the petition presented any substantially new arguments or merely repeated the positions already adjudicated by the lower courts.

The Court observed that the petition raised the same issues previously resolved by the trial courts and the Court of Appeals.