Case Summary (G.R. No. 191310)
Factual Background
The petitioners entered into a verbal lease with the previous owners of the property, Ernesto and Socorro Singson, agreeing to pay monthly rent. The Singsons later executed a real estate mortgage with the Bank, and due to their failure to repay, the Bank initiated foreclosure proceedings, leading to the transfer of ownership to the Bank. The Bank continued allowing the petitioners to occupy the property on a month-to-month basis despite accruing rental arrears.
Procedural History
On 30 January 1998, the Bank sent each petitioner a statement of their overdue rent and subsequently issued a final notice on 8 February 1998, demanding they vacate the premises. After their failure to comply, the Bank filed a complaint for unlawful detainer with the Metropolitan Trial Court (MTC). The MTC ruled in favor of the Bank, affirming valid grounds for ejectment due to non-payment of rent and the expiration of the lease agreement. The decision was upheld by the Regional Trial Court (RTC) and subsequently dismissed by the Court of Appeals (CA).
Issues and Rulings
The key issues presented were whether the MTC had jurisdiction over the unlawful detainer action and whether there existed valid grounds for the petitioners' ejectment. The CA upheld that the MTC had jurisdiction, stating that since the unlawful detainer action was based on the expiration of the lease, a prior demand to vacate was not a requirement under the applicable law. Moreover, it determined that petitioners were guilty of forum shopping when they filed multiple petitions, leading to the dismissal of their appeals.
Jurisdictional Concerns
Petitioners contended that jurisdiction was improperly established because the MTC's proceedings were initiated before the requisite five-day waiting period from the demand to vacate. However, the ruling clarified that the demand to vacate was unnecessary given the ground of expiration of the lease. Under Section 2 of Rule 70, demands are only required when the action is based on non-payment of rent or other violations, which was not the case here.
Grounds for Ejectment
Petitioners argued that the Bank could not rely on the expiration of the lease as a ground for ejectment since their verbal lease did not specify a duration. However, the Court noted that a lease, even a verbal one with monthly rent, is deemed month-to-month as per Article 1687 of the Civil Code. The Court ruled that the lease was effectively terminated when the Bank made a demand on 9 October 1997 for the petitioners to vacate the premises.
Application of Law
The decision cited B.P. Blg. 877 as the applicable rental law at the time, which allows ejectment for reasons including rent arrears and the expiration of the lease. The Court empha
...continue readingCase Syllabus (G.R. No. 191310)
Case Background
- This case involves a petition for review on certiorari with an urgent prayer for a temporary restraining order and/or writ of preliminary injunction.
- The petitioners are Alfredo Arquelada, Cresencia Egos, Nelson Egos, and others claiming rights and interest to occupy certain premises.
- The respondents are the Philippine Veterans Bank.
- The case concerns the reversal of a decision made by the Court of Appeals on June 22, 1999, which dismissed the petition for review filed by the petitioners.
- The appellate decision upheld the ruling of the Regional Trial Court (RTC) and the Metropolitan Trial Court (MTC), which ordered the ejectment of the petitioners from the premises.
Factual Antecedents
- The petitioners were lessees of a fourteen-door apartment located at No. 1708 M. Lazaro corner M. Hizon Streets, Sta. Cruz, Manila.
- The apartments were originally owned by spouses Ernesto and Socorro Singson, who entered into a verbal lease agreement with the petitioners.
- The spouses later executed a real estate mortgage on the property with the Philippine Veterans Bank.
- Due to default in loan payments, the Bank foreclosed on the mortgage, and ownership of the properties transferred to the Bank.
- Following the foreclosure, the Bank allowed the petitioners to continue occupying the apartments under a month-to-month lease.
Rental Arrearages
- The petitioners accrued significant arrearages in rental payments:
- Total arrearages for each petitioner amounted to thousands of pesos, with some owing as much as P35,930.00.
- On January 30, 1998, the Bank sent statements of account to each petitioner detailing their outstanding rental debts.
- Multiple demands for payment were made, which went unheeded, leading to a final notice on February 8, 1998, urging the peti