Case Summary (G.R. No. 124213)
Facts of the Case
The appeal arises from the judgment dismissing Lim Sr.'s complaint against Isabello P. Lim regarding rental disputes for two doors of an accessorial building located on Misericordia Street. Lim Sr., who had been a long-time lessee, was allowed to occupy the two doors starting July 15, 1953, without a definite rental agreement, other than a verbal understanding to match the rents paid by other lessees. In January 1954, Lim Sr. proposed a rent of P600 for both doors, which was rejected by the defendant, leading to an eventual deposit of P1,000 made by the plaintiff to cover rental payments starting January 1954. Subsequently, Lim Sr. consistently offered P600 as rental, but this was declined by the defendant, who later demanded P700.
Procedural History
As the situation deteriorated over rental payments, Lim Sr., fearing unlawful detainer action, continued to deposit the rent with both the defendant and the court. The initial complaint, seeking a court determination of the rental amount, was filed on August 27, 1954. The defendant moved to dismiss the case, arguing that it constituted a consignation, which was not the appropriate remedy, and asserted that the matter should be addressed as a forcible entry and unlawful detainer case under Rule 72 of the Rules of Court.
Issue of Dismissal
The court dismissed the complaint, determining that the dispute over rentals was connected to a pending ejectment case filed by the defendant shortly after Lim Sr.'s complaint. The court concluded that Lim Sr. lacked a cause of action; there was no violation of his rights, nor any obligation breached by the defendant. Furthermore, any proposed rental amount had not been mutually agreed upon, and the defendant had the right to impose a rental amount which Lim Sr. had to accept or vacate the property.
Legal Principles Involved
The court asserted that only the property owner has the authority to fix rental amounts, and the judicial system cannot enforce rentals against the will of the lessor. Thus, it reiterated that a lease implies consensual agreement terms, and without such consent, no legal lease can exist. The ruling referenced the established legal principle that disputes regarding rental
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Background of the Case
- The case involves an appeal from a judgment rendered by the Court of First Instance of Manila, which dismissed the plaintiff's complaint.
- The plaintiff, Lim Sr., was an old lessee of the premises in question, located on Misericordia Street, owned by the defendant, Isabelo P. Lim.
- Following the reconstruction of the building, the plaintiff was allowed to occupy two doors starting July 15, 1953, without a specified amount of rent, only that it would be comparable to what other lessees were paying.
Rent Negotiations
- In January 1954, the plaintiff proposed a rental rate of ₱300 per door, totaling ₱600 for both, which was the rate paid by another lessee in better quarters.
- The defendant, however, could not settle on a rental amount, leading to an agreement that the plaintiff would deposit ₱1,000, which would cover rent from January 1954 onward.
- Despite offering ₱600 monthly thereafter, the defendant refused to accept the payments.
Demand for Rent
- On April 2, 1954, the defendant demanded ₱700 monthly from January 1, 1954, as rental payment.
- Fearing an unlawful detainer action from the defendant, the plaintiff continued to deposit ₱600 monthly as rent, first with the defendant and later with the court.
Plaintiff's Complaint
- The plaintiff sought a court determination of the rental amount to be ₱600, effe