G.R. No. 187836 - Social Justice Society Officers vs. Lim

Case Summary (G.R. No. 187836)

Factual Background

Agapito Manuel rented an apartment unit from Spouses Jesus de Jesus and Carmen de Jesus on a month-to-month tenancy at a rental of P466.00 payable in advance. The petitioner failed to pay rentals beginning May 1987 and continued in arrears through the filing of the complaint on August 31, 1987. The lessors’ counsel sent a demand letter on July 9, 1987, received July 14, 1987, requiring payment and vacation within five days. The petitioner replied on July 15, 1987, stating that he had deposited the rentals in United Coconut Planters Bank, Taft Avenue Branch, Account No. 8893 in the name of his son, Mario Manuel, and that the amount could be withdrawn upon notice. Subsequent correspondence from the lessors’ counsel of August 14, 1987, requested payment to counsel’s office; this was received August 18, 1987. The petitioner then wrote on August 24, 1987, proposing that the arrears be paid at his house, a proposal the lessors did not accept.

Trial Court Proceedings

The Metropolitan Trial Court of Manila heard the ejectment action for nonpayment of rent. After submission of affidavits and position papers, the trial court rendered judgment on April 6, 1989, ordering the defendant to vacate and surrender possession of Door No. 2444, directing the defendant to pay P466.00 per month from May 1987 until actual vacation, and awarding P500.00 as attorney’s fees plus costs to the plaintiffs.

Regional Trial Court and Court of Appeals Proceedings

On appeal, the Regional Trial Court of Manila, Branch 35, affirmed the trial court’s judgment in its decision dated September 20, 1989. The petitioner elevated the case to the Court of Appeals, which, in CA-G.R. SP No. 18961, denied due course to the petition for review and dismissed it for lack of merit in a decision dated January 29, 1990. The petitioner’s motion for reconsideration was denied by the Court of Appeals in a resolution dated March 5, 1990.

The Parties’ Contentions on Review

On petition before the Supreme Court, Agapito Manuel advanced two principal grounds. First, he asserted a supervening change in circumstances: an alleged National Housing Authority award dated April 6, 1990 granted the lot on which the leased structure stood to him and other tenants, disqualifying the private respondents and either obliging them to sell the structure or dismantle it. Second, he argued that the private respondents were in mora accipiendi for refusing to accept rental payments and that he had in fact made the rentals available or deposited them, rendering consignation unnecessary or cured. He further urged that the NHA award made the issue of payment moot and implicated public policy favoring protection of actual occupants.

Issues Presented

The Supreme Court framed the material issues as whether the alleged NHA award altered the juridical relation between lessee and lessors so as to bar ejectment; whether the petitioner’s purported deposit cured nonpayment under the doctrine of consignation; and whether the private respondents’ alleged refusal to accept payment constituted valid defense to ejectment proceedings instituted for three months’ arrears under Section 5(b) of Batas Pambansa Blg. 25, as amended.

Supreme Court’s Ruling

The Supreme Court denied the petition and affirmed the judgment of the Court of Appeals. The Court held that the NHA award was immaterial to the ejectment action and that the established lessor-lessee relationship and the evidence of rental arrears supported the dispossessory judgment. The Court ruled that the petitioner’s claimed deposit did not satisfy the statutory requisites of consignation under Section 5(b) of B.P. Blg. 25, as amended, and that the owners’ failure or refusal to accept payment did not excuse the lessee from complying with the statutory method of consignation.

Legal Basis and Reasoning

The Court reasoned that an award of the lot by the NHA does not automatically vest ownership of the leased structure in the petitioner and that the rules on accession are inapplicable where an existing juridical relation of lessor and lessee subsists; their agreement and the Civil Code provisions on obligations and special contracts supply the governing regime. The Court reiterated the settled doctrine that a tenant in possession cannot, in an action for possession, controvert the title of the landlord or assert rights inconsistent with the landlord’s title while retaining possession; such contestation must be pursued in a separate and appropriate action. The Court emphasized that forcible entry and detainer proceedings are summary and that the fact of lease and its expiration or nonpayment are the determinative elements; ownership questions are unessential to such proceedings and should be litigated thereafter by the party restored to possession. The Court cited precedents supporting these principles, including Tiu vs. Court of Appeals, et al., Bautista, et al. vs. Gonzales, and other

Case Syllabus (G.R. No. 187836)

Parties and Posture

Agapito Manuel was the lessee and petitioner in an ejectment proceeding initially filed before the Metropolitan Trial Court of Manila as Civil Case No. 122136-CV.
Spouses Jesus de Jesus and Carmen de Jesus were the lessors and private respondents who instituted the ejectment action for non-payment of rentals.
The Metropolitan Trial Court rendered judgment for the plaintiffs on April 6, 1989, which was appealed to the Regional Trial Court of Manila, Branch 35 in Civil Case No. 89-48914.
The Regional Trial Court affirmed the MTC decision by judgment dated September 20, 1989.
The petitioner filed a petition for review with the Court of Appeals in CA-G.R. SP No. 18961, which the court denied by decision dated January 29, 1990 and denied the motion for reconsideration by resolution dated March 5, 1990.
The petitioner elevated the case to the Supreme Court by petition for review, which is the subject of this decision.

Key Facts

The private respondents owned an apartment unit rented by the petitioner on a month-to-month basis for a monthly rental of P466.00 payable in advance.
The petitioner failed to pay the corresponding rentals for the month of May 1987 and thereafter up to the filing of the complaint on August 31, 1987.
On July 9, 1987 the private respondents, through counsel, sent a demand letter to the petitioner which the petitioner received on July 14, 1987.
The petitioner replied by letter dated July 15, 1987 stating that the rentals had been deposited at United Coconut Planters Bank, Taft Avenue Branch, Account No. 8893 in the name of his son, and that they could be withdrawn upon notice of payment.
The private respondents’ counsel sent a letter dated August 14, 1987 requesting payment to his office, which the petitioner received on August 18, 1987.
The petitioner addressed another letter dated August 24, 1987 requesting that the rentals in arrears be paid to the private respondents at the petitioner’s house, and the private respondents did not comply with that request.
While the case was pending in the Court of Appeals, the National Housing Authority (NHA) purportedly awarded the lot where the subject structure stood to the petitioner and other tenants by an award dated April 6, 1990.

Issues

Whether the purported award by the NHA vested ownership of the structure on the petitioner and thereby rendered ejectment unjust or impossible.
Whether the private respondents were in mora accipiendi so that consignation by the petitioner was valid without strict compliance with statutory requisites.
Whether the petitioner effected a valid consignation under Section 5(b) of Batas Pambansa Blg. 25, as amended to extinguish arrearages and defeat ejectment.

Petitioner's Contentions

The petitioner contended that a new factual situation supervened in his favor when the NHA awarded the lot to him and other tenants and disqualified the private respondents from claiming the property.
The petitioner contended that the private respondents were in mora accipiendi and that he had continuously made available and deposited his rentals either in bank or in court.
The petitioner contended that the issue of payment of rentals was rendered moot and academic by the NHA award and by a governmental policy of protecting actual occupants.

Respondents' Contentions

The private respondents contended that the petitioner failed to pay rentals from May 1987 through the filing of the complaint and thus was in arrears for more than three months.