Title
Supreme Court
Sy-Vargas vs. Estate of Ogsos
Case
G.R. No. 221062
Decision Date
Oct 5, 2016
A lease dispute over agricultural land led to claims of unpaid rent and counterclaims for lost profits, with courts ruling on timeliness, counterclaim nature, and damages, ultimately reducing the award for unpaid rentals.

Case Digest (G.R. No. L-61323-24)
Expanded Legal Reasoning Model

Facts:

  • Lease Contract and Amendments
    • On February 10, 1994, Rolando Ogsos, Sr. leased from the Heirs of Fermina Pepico (including petitioner Elizabeth Sy-Vargas and her sister Kathryn) approximately 23 hectares of agricultural land in Manjuyod, Negros Oriental, for a rental of 230 piculs (290.95 lkg.) of centrifugal sugar per crop year from 1994–1995 to 2000–2001.
    • On June 5, 1996, the lease was extended to end with the 2003–2004 crop year due to improvements introduced by respondents. On December 30, 1996, the lease rental was amended to P150,000.00 cash per crop year, starting 1996–1997.
  • Litigation in the RTC and CA
    • Petitioners filed on April 27, 2000 a complaint for specific performance and damages for unpaid sugar rentals from 1994–1999, excluding 1999–2000 when respondents allegedly abandoned the premises. Respondent Rolando Ogsos, Jr. answered belatedly in December 2002. The RTC initially declared respondents in default, but the CA later ordered the answer admitted.
    • Respondents counterclaimed for lost profits from crop years 1999–2004, alleging that petitioners unlawfully took possession and harvested sugarcane in December 1998, thus depriving respondents of enjoyment of the leased premises. After various pre-trial orders and motions, the RTC in a July 2, 2007 Decision granted the counterclaim, awarding P10,391,981.76 plus moral, exemplary damages, attorney’s fees, and costs.
    • In CA G.R. CV No. 03710, the Court of Appeals on February 28, 2014 affirmed the RTC’s award of P10,391,981.76 but deleted moral and exemplary damages, attorney’s fees, and costs for lack of bad faith. Petitioners’ timely motion for reconsideration was denied on October 1, 2015 as allegedly filed out of time.

Issues:

  • Whether the CA correctly ruled that petitioners’ motion for reconsideration was filed out of time.
  • Whether respondents’ counterclaim is compulsory or permissive and thus whether docket fees were required.
  • Whether respondents are entitled to their counterclaim for lost profits.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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