Case Digest (G.R. No. 177809) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Omar and Moshhiera Latip vs. Rosalie Palaaa Chua (G.R. No. 177809, October 16, 2009), respondent Rosalie Palaaa Chua owned Roferxane Building, a commercial property at No. 158 Quirino Avenue corner Redemptorist Road, Parañaque City. On July 6, 2001, she filed a complaint for unlawful detainer and damages against petitioners, Omar and Moshhiera Latip, attaching a contract of lease dated December 1999 for two cubicles (56 sqm) at P60,000 monthly, subject to a 10% annual increase, a six-year term ending December 2005, and prohibitions on sub-letting and alterations. The Latips occupied the cubicles in December 1999. They countered that they paid P2,570,000 in one lump sum—evidenced by three receipts in Rosalie’s handwriting—as purchase of lease rights, thereby novating the lease. The Metropolitan Trial Court (MeTC) granted Rosalie’s ejectment petition, ordered back‐rent plus attorney’s fees. On appeal, the Regional Trial Court (RTC) reversed, finding the lease contract i Case Digest (G.R. No. 177809) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Contract
- Petitioners Spouses Omar and Moshiera Latip (lessees) and Respondent Rosalie Palaña Chua (lessor) executed a Contract of Lease in December 1999 for two cubicles in Roferxane Building, Parañaque City.
- Lease terms: six-year term (Dec. 1999–Dec. 2005); monthly rent ₱60,000 with annual 10% increase; lessees to pay utilities; no subletting or alterations without written consent; liquidated damages for early termination.
- Notarization: acknowledged before Notary Public but missing exact dates; signature of Rosalie and both spouses present; Ferdinand Chua (Rosalie’s husband) did not sign the lease.
- Payment and Dispute
- Spouses Latip occupied the cubicles in December 1999 and later paid Rosalie three receipts totaling ₱2,570,000 (₱2,000,000 check; ₱500,000 cash; ₱70,000 cash).
- In mid-2000, Rosalie demanded back rentals and, upon non-payment, filed an unlawful detainer complaint for unpaid rent and damages.
- Procedural History
- MeTC (Branch 78) granted ejectment and awarded Rosalie arrearages: ₱720,000 (Dec 1999–Dec 2000), ₱72,000/month (Jan 2001–Dec 2002) plus 10% annual increases, attorney’s fees and costs.
- RTC (Branch 274) reversed MeTC: upheld a subsisting six-year lease fully paid by Spouses Latip; awarded them moral (₱1,000,000), exemplary (₱500,000) damages, attorney’s fees and costs.
- CA (G.R. SP No. 89300) reversed RTC and reinstated MeTC decision, taking judicial notice of local “goodwill money” practice.
Issues:
- Did the CA correctly take judicial notice of a local practice of paying “goodwill money” to lessors?
- Were the receipts totaling ₱2,570,000 evidence of full payment of the six-year lease rentals?
- Is there a valid lease obligation and, if so, are the Spouses Latip liable for unpaid rentals and subject to ejectment?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)