Case Digest (G.R. No. 224022)
Facts:
Teodorico A. Zaragoza v. Iloilo Santos Truckers, Inc., G.R. No. 224022, June 28, 2017, First Division, Perlas-Bernabe, J., writing for the Court.Petitioner Teodorico A. Zaragoza purchased Lot No. 937‑A on June 26, 2003 from his parents and subsequently learned that a 1,000‑sq. m. portion had been leased by his father to respondent Iloilo Santos Truckers, Inc. for eight years beginning December 5, 2003, renewable for another eight years at respondent’s option; respondent paid monthly rentals (nominally P10,000 or varying amounts inclusive of VAT) under the lease.
After Florentino Zaragoza’s death, disputes over whom to pay arose and respondent filed an interpleader action in the Regional Trial Court, Branch 24 (RTC‑Br. 24), Civil Case No. 07‑29371; RTC‑Br. 24 issued orders (June 22, 2010; Aug. 17, 2010) dismissing the interpleader but advising that consignation was available as a remedy. Pursuant thereto respondent filed a Consolidated Report (Jan. 26, 2011) and a Manifestation and Notice (May 30, 2011) that it had consigned P521,396.89 with RTC‑Br. 24, which it characterized as rentals for February 2007 to March 2011.
Petitioner sent a demand dated May 24, 2011 claiming unpaid rentals (February 2007 to May 2011) totaling P752,878.72 and giving respondent 15 days to vacate. Respondent replied that it had consigned the rentals and denied liability for interest; petitioner replied June 9, 2011 pointing out the consignation covered only February 2007 to March 2011 and that the consigned amount was insufficient to satisfy his demand. When respondent did not make additional consignations or payments, petitioner filed a complaint for unlawful detainer on June 21, 2011 in the Municipal Trial Court in Cities (MTCC), Iloilo City, Branch 10, Civil Case No. 32‑11.
The MTCC, in a Decision dated December 29, 2011, ruled for petitioner, ordered respondent’s ejectment, awarded back rentals at P10,000.00 per month from February 2007 until vacation, plus 12% legal interest from extrajudicial demand, attorney’s fees (P20,000), litigation expenses (P50,000), and costs. The MTCC held respondent’s consignation before RTC‑Br. 24 was void and did not relieve respondent of its obligations. Respondent appealed to the Regional Trial Court, Branch 23 (RTC‑Br. 23), Civil Case No. 12‑31294.
RTC‑Br. 23, in a Decision dated July 5, 2013, reversed and dismissed the MTCC, finding respondent’s consignation valid because it was made pursuant to RTC‑Br. 24’s orders, was effected prior to the MTCC suit, petitioner knew of it and withdrew the consigned amounts; hence consignation released respondent from its rental obligations. Respondent then sought relief in the Court of Appeals (CA) via CA‑G.R. CEB‑SP No. 07839.
The CA affirmed RTC‑Br. 23 in a Decision dated July 22, 2015, holding that respondent acted in good faith, was ready and willing to pay but unsure whom to pay, and th...(Subscriber-Only)
Issues:
- Did the Court of Appeals correctly rule that petitioner could not eject respondent because respondent fully complied with its obligation to pay monthly rent through consi...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)