Case Digest (G.R. No. L-61323-24) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Elizabeth Sy-Vargas v. The Estate of Rolando Ogsos, Sr. and Rolando Ogsos, Jr., the heirs of Fermina Pepico (including petitioner Elizabeth Sy-Vargas and her sister Kathryn T. Sy) leased five parcels of agricultural land in Maaslum, Manjuyod, Negros Oriental to Rolando Ogsos, Sr. on February 10, 1994 for sugar delivery as rental. The lease was extended in June 1996 and amended on December 30, 1996 to P150,000 cash per crop year. The lessors filed Civil Case No. 12708 in the Regional Trial Court (RTC) of Dumaguete City on April 27, 2000, claiming unpaid sugar rentals from 1994–1999, excluding 1999–2000 when respondents allegedly abandoned the land. Respondents answered in December 2002, prompting a default declaration that was later set aside by the Court of Appeals (CA) to admit the answer. Respondents counterclaimed for lost profits from 1999 to 2004, alleging that petitioners unlawfully took possession and appropriated cane under pretext of unpaid rent, impairing their enjo Case Digest (G.R. No. L-61323-24) Expanded Legal Reasoning Model
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)