Case Summary (G.R. No. 147372)
Background Information
MuAoz contended that she acquired ownership of the property and subsequently allowed the petitioners to occupy specified doors of the apartment building on said land. Following a period of tolerance, she demanded payment of rents starting February 1997 but claimed that the Lanuzas failed to comply and refused to vacate the property, thus prompting the unlawful detainer suit. The initial complaint was filed in the Metropolitan Trial Court (MTC) of Muntinlupa City.
Jurisdictional Issues
The MTC dismissed MuAoz's complaint, determining it did not possess jurisdiction as there was no clear evidence of demand to vacate made prior to the filing of the complaint. The ruling was upheld by the Regional Trial Court (RTC). It established that demand was a jurisdictional prerequisite for the action, as MuAoz sought to claim back rental payments alongside recovery of possession.
Petition to the Court of Appeals
MuAoz appealed the dismissal to the Court of Appeals, which reversed the RTC’s ruling and remanded the case back to the MTC for further proceedings. The appellate court posited that the cause of action was based on the cessation of tolerance by the respondent for the Lanuzas' occupancy, rather than on the non-payment of rentals.
Legal Arguments Presented
Petitioners argued that the appellate court erred by not requiring a demand to vacate prior to filing the unlawful detainer case, claiming that this violated Section 2, Rule 70 of the 1997 Rules of Civil Procedure. They further claimed that precedents set in previous Supreme Court decisions mandated a demand for the case to proceed.
Court of Appeals' Reasoning
The Court of Appeals clarified that the basis of the complaint was the withdrawal of MuAoz’s tolerance of the Lanuzas' continued occupancy, distinguishing it from typical cases of unlawful detainer where rental payments are due. It was determined that as no formal lease existed, the allegations of non-payment could not serve as grounds for unlawful detainer.
Supreme Court's Review
Upon review, the Supreme Court found the factual findings of the appellate court to be binding and held that a demand to vacate is indeed not necessary in cases where the cause of action is based on withdrawal of tolerance. The Court emphasized that the legal framework referenced by the pet
...continue readingCase Syllabus (G.R. No. 147372)
Case Overview
- This case concerns a review on certiorari of the Decision dated December 28, 2000, from the Court of Appeals regarding the unlawful detainer complaint filed by Ma. Consuelo MuAoz against petitioners Caezar Z. Lanuza and Asteria Lanuza.
- The Court of Appeals set aside the Regional Trial Court (RTC) decision which had affirmed the Metropolitan Trial Court (MTC) dismissal of the unlawful detainer complaint for lack of jurisdiction.
- The petitioners also contest the CA Resolution dated March 7, 2001, that denied their motion for reconsideration.
Factual Background
- Ma. Consuelo MuAoz claims ownership of a parcel of land in Alabang, Muntinlupa, along with a nine-door apartment, evidenced by Transfer Certificate of Title No. 207017.
- The property was allegedly acquired from the petitioners through a Deed of Absolute Sale on August 7, 1996.
- MuAoz tolerated the petitioners' occupation of the premises until January 1997, after which she demanded rental payments for their continued stay.
- The petitioners, however, assert that they are the lawful owners of the property and deny having sold it to MuAoz.
Legal Proceedings
- The