Case Summary (G.R. No. 268216)
Factual Background
The lease agreement commenced on October 1, 2012, with a monthly rental of PHP 6,000.00. However, starting April 1, 2017, the respondents failed to make rental payments despite several demands from Reyes to settle the amounts due and vacate the premises. The dispute escalated when Reyes filed a complaint with the Lupon ng Tagapamayapa of Barangay Payatas, which the Pachecos allegedly ignored, prompting the issuance of a Certificate to File Action on July 10, 2017.
Legal Proceedings Initiated
Efforts by the respondent to formally communicate the demands for payment and vacate were documented, including a personal demand letter delivered by a law intern. This demand was reportedly refused by the Pachecos. Subsequently, on April 13, 2019, Reyes, with the help of the University of the Philippines-Office of Legal Aid, filed a complaint for unlawful detainer and damages. The complaint was acknowledged by the Metropolitan Trial Court (MeTC), which later issued a ruling finding in favor of the respondent.
Rulings of the Lower Courts
The MeTC's decision on September 21, 2020, confirmed that the elements of unlawful detainer were substantiated through adequate proof. The court emphasized that since the lease was valid and actively acknowledged by the Pachecos, their subsequent refusal to pay rent and assertion of ownership claims were legally untenable. They were found to be effectively estopped from contesting ownership due to their prior acknowledgment of the lease agreement.
Regional Trial Court Affirmation
Petitioners escalated the matter to the Regional Trial Court (RTC), which upheld the MeTC ruling in its decision dated July 9, 2021, affirming that the Pachecos' possession became unlawful following their default in meeting rental payments. The court reiterated that the petitioners could not deny the respondent's title as the lessor due to legal stipulations under the Rules of Court.
Court of Appeals Dismissal
The Court of Appeals (CA) subsequently dismissed the petition for certiorari filed by the Pachecos, rejecting the argument that they presented a valid case for grave abuse of discretion. The CA highlighted procedural deficiencies in the petition, including the absence of a verification and a certification against forum shopping, essential components required for such legal filings.
Supreme Court Decision
Upon elevating the matter to the Supreme Court, the Court scrutinized the CA's dismissal and found no reversible errors. It clarified that the petition for certiorari was an inappropriate remedy given that an appeal was s
...continue readingCase Syllabus (G.R. No. 268216)
Background and Facts of the Case
- Respondent Jimmy F. Reyes is the lawful possessor of the property located at No. 39 Visayas Street, Group 3, Area B, Payatas, Quezon City, having acquired it via Subrogation/Transfer of Rights and Improvement dated February 5, 2004, from Benedicto Roquid.
- Petitioner Caridad Pacheco and her late husband, Ramon Pacheco, Sr. (spouses Pacheco) entered into a contract of lease with respondent on September 20, 2012, agreeing to pay a monthly rental of PHP 6,000 starting October 1, 2012.
- Beginning April 1, 2017, spouses Pacheco failed to pay monthly rentals and despite repeated demand letters dated August 5, 2017, and February 11, 2019, they neither paid the arrears nor vacated the property.
- The respondent filed a complaint before the Lupon ng Tagapamayapa of Barangay Payatas, which spouses Pacheco ignored, resulting in a Certificate to File Action issued on July 10, 2017.
- On February 13, 2019, respondent through UP-OLA's law intern personally tendered a demand letter to spouses Pacheco, which they allegedly refused to receive; an Affidavit of Service by the law intern was executed to confirm personal tender.
- Subsequently, respondent filed a complaint for Unlawful Detainer and Damages on April 13, 2019, and summons were served on April 22, 2019.
- Spouses Pacheco, through their counsel Atty. Romeo N. Bartolome, filed an Answer with Compulsory Counter Claim denying respondent's cause of action, claiming ownership of the property via a Deed of Assignment from the Acopiado estate.
- They also denied receipt of demand letters, contending their refusal to receive was justified based on ownership claims, and prayed for dismissal based on prescription, alleging continuous possession for over 30 years and lapse of the one-year filing period after demand.
Ruling of the Metropolitan Trial Court (MeTC)
- The MeTC, in its September 21, 2020 Decision, ruled in favor of respondent, granting the complaint for unlawful detainer and damages.
- The court found that respondent proved all elements of unlawful detainer by preponderance of evidence.
- The lease contract executed by the parties was judicially admitted by spouses Pacheco; the latter admitted cessation of rental payments after questioning respondent’s ownership.
- The MeTC cited Section 2(b), Rule 131 of the Rules of Court, emphasizing that a tenant cannot deny the landlord’s title at the start of their relationship.
- Based on the breach of payment obligation, spouses Pacheco were estopped from contesting resp