Title
Chua Gui Seng vs. General Sales Supply Co., Inc.
Case
G.R. No. L-3974
Decision Date
Apr 28, 1952
Lessee failed to pay rent, vacated premises; landlord demanded back rent and forfeited deposit. Court upheld forfeiture but limited it to half, balancing contract terms and equity.

Case Summary (G.R. No. 235483)

Facts of the Case

On June 1, 1948, Chua Gui Seng leased a portion of his property to General Sales Supply Co., Inc. for a year at a monthly rate of P1,500. According to the lease terms, the defendant was to deposit P3,000, which would be applied to the last six months of rent. The contract specified that if the lessee failed to fulfill the lease terms, the deposit would be forfeited. The defendant, however, failed to pay the September and October 1948 rental fees.

Counsel Communication

On October 8, 1948, attorney Jesus B. Santos, representing Chua Gui Seng, informed General Sales Supply Co. of its rental arrears and granted a 15-day grace period for the lessee to vacate the premises. The letter also indicated that if the defendant settled the P3,000 owed, Chua Gui Seng would not pursue eviction or enforce the forfeiture of the deposit.

Ejectment Proceedings

Following the non-payment, on October 18, 1948, Chua Gui Seng filed an ejectment complaint in the Municipal Court of Manila. The Municipal Court ruled in favor of Chua Gui Seng on October 29, 1949. Subsequently, General Sales Supply Co. sought to appeal the decision in the Court of First Instance of Manila.

Stipulation of Facts

In the Court of First Instance, the parties entered into a stipulation confirming the existence of the lease, the acknowledgment of the unpaid rent from September and October, and the deposit of P3,000. It was noted that the defendant vacated the premises on October 31, 1948, shortly after the Municipal Court's judgment was announced.

Trial Court's Reasoning

The trial court dismissed the ejectment case, interpreting Atty. Santos’s communication as an amendment to the lease contract. The court suggested that the 15-day grace period granted to the defendant provided an opportunity to remedy the outstanding rental dues, and that by vacating the property, the defendant had evaded the responsibility of paying the back rent.

Supreme Court Findings

The Supreme Court overturned the trial court's decision, asserting that Atty. Santos's letter did not provide a legal basis for General Sales Supply Co. to vacate without satisfying its rent obligations. The court emphasized that the letter maintained the enforcement of the lease and the forfeiture of the deposit was still valid, so long as the rental deb

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