Facts:

The case involves Emilia Tengco as the petitioner and Benjamin Cifra, Jr. as the respondent. The events leading to the case began on September 16, 1976, when Benjamin Cifra, Jr. filed an action for unlawful detainer against Emilia Tengco in the Municipal Court of Navotas, Metro Manila, under Civil Case No. 2092. Cifra claimed to be the owner of the premises located at No. 164 Int., Gov. Pascual St., Navotas, which he had leased to Tengco. He alleged that Tengco failed to comply with the lease terms by not paying the stipulated rentals despite repeated demands. After trial, the Municipal Court ruled in favor of Cifra, ordering Tengco to vacate the premises and pay arrears in rentals amounting to P376.00, plus P12.00 monthly until the premises were vacated, and P200.00 for attorney's fees.

Dissatisfied with the Municipal Court's decision, Tengco appealed to the Court of First Instance of Rizal, which was docketed as Civil Case No. C-6625. On May 18, 1978, the Court of...

Facts:

1. Lease Agreement and Ownership Claim

   • Benjamin Cifra, Jr., the private respondent, claimed ownership of the premises at No. 164 Int., Gov. Pascual St., Navotas, Metro Manila, which he leased to Emilia Tengco, the petitioner.
   • On September 16, 1976, Cifra filed an action for unlawful detainer against Tengco for her failure to pay the stipulated rentals despite repeated demands.

2. Judgment of the Municipal Court

   • The Municipal Court of Navotas ruled in favor of Cifra, ordering Tengco to vacate the premises and pay P376.00 in arrears, P12.00 monthly until vacated, P200.00 in attorney’s fees, and costs of suit.

3. Appeal to the Court of First Instance

   • Tengco appealed to the Court of First Instance of Rizal, which affirmed the municipal court’s decision in toto on May 18, 1978.

4. Appeal to the Court of Appeals

   • Tengco filed an "Appeal by Way of Certiorari" with the Court of Appeals, which dismissed her petition on August 29, 1978, finding no merit in her claims.

5. Petitioner’s Contentions

   • Tengco argued that:
     • Cifra was not the owner of the leased premises.
     • The lessor was guilty of mora accipiendi (delay in accepting payment).
     • Her version of the facts was more credible.
     • Laches barred Cifra’s claim.
     • Cifra failed to establish a cause of action.

Issue:

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Ruling:

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Ratio:

1. Ownership of the Leased Premises

   • A tenant cannot deny the title of their landlord at the commencement of the lease. The trial court’s finding that Cifra is the owner is entitled to respect, and Tengco failed to present sufficient evidence to overturn this finding.

2. Mora Accipiendi

   • Tengco’s failure to consign the unpaid rentals in court, as required under Article 1256 of the Civil Code, negates her claim of mora accipiendi.

3. Credibility of Facts

   • The trial court’s findings on the facts are binding unless there is a showing of overlooked or misapplied evidence. Tengco failed to demonstrate such errors.

4. Laches

   • Laches does not apply because Cifra’s demand for payment and filing of the complaint were made within a reasonable time after Tengco’s default.

5. Cause of Action

   • Cifra established a valid cause of action for unlawful detainer based on Tengco’s failure to pay rentals despite demand, entitling him to eject her from the premises.