Case Summary (G.R. No. L-15022)
Ejectment Proceedings Initiated by Petitioners
- Petitioners initiated ejectment proceedings against Westminster High School on May 21, 1958.
- The basis for the ejectment was a lease contract dated November 15, 1946, for a parcel of land in Tondo, Manila, with a monthly rental initially set at P1,200.00, later reduced to P1,000.00.
- The lease stipulated that rentals were to be paid "at the end of each month."
- Respondent admitted the existence of the lease but claimed a practice of deferred payment during the summer months of April and May.
- Respondent deposited the arrears with the court before the hearing, and the Municipal Court ruled in favor of the petitioners on July 9, 1958.
Judgment and Appeal Process
- The Municipal Court's judgment required the respondent to pay P1,000.00 for the rental period from June 16 to July 15, 1958, and subsequent monthly payments.
- The respondent appealed the judgment to the Court of First Instance of Manila, where it continued to deposit rental payments but failed to adhere to the stipulated payment schedule.
- The respondent's deposits were consistently late, prompting the petitioners to file a motion for execution of the Municipal Court's judgment on October 1, 1958.
Court's Ruling on Payment and Execution
- The Court of First Instance denied the petitioners' motion for execution, stating that the Municipal Court's judgment did not explicitly mention the existence of a lease contract.
- The court interpreted Section 8, Rule 72 of the Rules of Court, which outlines conditions for immediate execution of judgments, emphasizing the need for a finding of a lease contract.
- The court concluded that the respondent's late payments were permissible under the second mode of payment outlined in the rule.
Interpretation of Section 8, Rule 72
- Section 8, Rule 72 provides two modes of payment during an appeal: payment as per the lease contract or, in the absence of a contract, payment of the reasonable value of use and occupation.
- The respondent's late deposit on October 1, 1958, was deemed compliant with the second mode of payment.
- The court's interpretation of the phrase "on or before the tenth day of each calendar month" was challenged, as it applied only in the absence of a contract.
Existence of Lease Contract and Its Implications
- The petitioners argued that the existence of a lease contract was undisputed, as the respondent admitted to its existence in their answer.
- The judgment of the Municipal Court, while lacking an explicit statement of the lease, contained sufficient information regarding the rental amount and payment terms.
- The court's requirement for an...continue reading