Title
Consumido vs. Ros
Case
G.R. No. 166875
Decision Date
Jul 31, 2007
Petitioner defaulted on lease payments; respondents claimed landlord status but failed to prove real party-in-interest. SC ruled in favor of petitioner, reinstating dismissal of ejectment suit.
lease agreement
ejectment suit
reversal

Case Summary (G.R. No. 166875)

Factual Background

In 1995, Ramon Saura, Sr. allegedly entered into two lease contracts with Digna Consumido for Units 982 and 980 on A.H. Lacson Street, Sampaloc, Manila, at monthly rents of P6,400.00 and P6,000.00 respectively. Respondents Ramon Saura, Jr. and Fatima Saura averred that petitioner defaulted on rentals for Unit 982 in the last quarter of 1996 and for Unit 980 in August 1997; they made repeated demands, which petitioner allegedly ignored. Petitioner answered that she had contracted with the late Ramon Saura, Sr., who organized Villa Governor Forbes Corporation (VGFC) as administrator of the premises; she averred that she paid rents to respondents until June 1999, and later discovered that Sandalwood Real Estate Development Corporation (SREDC) had acquired title to the premises on April 18, 1995, prompting negotiations with SREDC to continue occupancy.

Metropolitan Trial Court Decision

After summary proceedings, the Metropolitan Trial Court, Branch 28, Manila, dismissed the ejectment complaint by decision dated April 19, 2002. The MeTC found that ownership of the premises was the subject of pending litigation between respondent Ramon Saura, Jr. and SREDC, VGFC, and other heirs of Ramon Saura, Sr. It further found that VGFC, as lessor, had previously sued to eject other lessees and that respondents had acted merely as administrators or representatives of VGFC; consequently, the MeTC declared respondents not to be the real parties-in-interest and dismissed the suit.

Regional Trial Court Decision

The Regional Trial Court reversed the MeTC on the ground that petitioner continued to remit rentals to respondents after they assumed administration following the death of Ramon Saura, Sr., and that respondents thereby acquired the material possession of the leased premises. The RTC found that the premises had been the ancestral home of respondents and that they remained in possession despite the disputed sale to SREDC. In a decision dated September 17, 2002, the RTC ordered petitioner to vacate, to pay unpaid rentals in the amount of Php714,800.00 from 1996 to December 2001 and continuing until vacancy, to pay Php20,000.00 as attorney’s fees, and to pay costs.

Court of Appeals Decision

On appeal, the Court of Appeals affirmed the RTC in a decision dated September 13, 2004 and denied reconsideration in a resolution dated January 24, 2005. The appellate court relied on petitioner’s admission that she remitted rentals to respondents and held that petitioner was precluded from controverting the title of her landlord or asserting any right inconsistent with that relation. The CA concluded that respondents had established a better right of possession and were the proper parties to seek ejectment.

Issues Presented

The principal issue was whether respondents had established that they were the landlords or successors-in-interest and therefore the real parties-in-interest entitled to maintain an action for unlawful detainer against Digna Consumido. Ancillary issues included whether petitioner was estopped from denying a landlord–tenant relationship by reason of her payment of rents to respondents, and whether acceptance of rents alone sufficed to confer landlord status.

Parties' Contentions

Petitioner contended that she had contracted with the late Ramon Saura, Sr. and that VGFC was the lessor; she maintained that respondents never established landlord status and therefore lacked standing as real parties-in-interest. Respondents argued that petitioner’s repeated payment of rentals to them after Saura, Sr.'s death amounted to an acknowledgment that they were her landlords or successors-in-interest and that petitioner was estopped from denying the landlord–tenant relation.

Supreme Court Ruling

The Court granted the petition for review on certiorari, reversed and set aside the Court of Appeals Decision dated September 13, 2004 and Resolution dated January 24, 2005, and reinstated the Metropolitan Trial Court decision dismissing the ejectment suit. The Court ordered costs against respondents.

Legal Basis and Reasoning

The Court reasoned that an action must be prosecuted by the real party in interest, defined as the person who possesses the substantive legal right sought to be enforced, and that a party without such interest cannot invoke the court’s jurisdiction. Citing Borlongan v. Madrideo and other precedents, the Court affirmed that in unlawful detainer the real party in interest is the landlord, vendor, vendee, or other person whose right to possession has been terminated. The records showed that petitioner did not contract with respondents. The Court found respondents produced only bare allegations and evidence that they had accepted rental payments. That fact alone did not establish ownership or succession to the landlord’s rights. The Court emphasized that a corporation acts only through officers or agents, and that it was plausible that Ramon Saura, Sr. acted for VGFC when the leases were made. Because respondents failed to show authority to prosecute the ejectment in the name of the true owner or sufficient proof that they themselves were landlords, they did not meet the plaintiff’s preponderance burden of proof in civil cases. The Court further addressed estoppel, stating that its invocation requires unequivocal and intentional conduct and three elements: lack of knowledge and means of knowledge of th

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