Case Summary (G.R. No. 18806)
Factual Background
The municipality of Moncada entered into a lease agreement with Pio Cajuigan, who was responsible for paying a total of P3,710 in quarterly installments. Cajuigan failed to meet his payment obligations and was eventually granted extensions. However, he claimed that he attempted to tender payment on multiple occasions, which the municipal treasurer allegedly refused. The lease was rescinded, and Cajuigan was forcibly evicted from the leased premises. The municipality subsequently filed a complaint claiming unpaid rents, penalties, and costs, leading to a judgment against the defendants.
Procedural History and Lower Court Findings
The Court of First Instance of Tarlac, led by Judge Julio Llorente, found in favor of the municipality, awarding it P1,855 for unpaid rents, penalties, and interest. The defendants' cross-complaint for damages was denied. The defendants appealed, arguing primarily that non-compliance was due to the municipality's actions and that the eviction was illegal.
Appeal and Issues Raised
On appeal, the defendants raised several errors related to the trial court's findings, alleging that the lower court erroneously attributed the non-payment of rent to Cajuigan, mismanaged the facts regarding payments, and failed to acknowledge their claims properly. The appeal also contended that the eviction of Cajuigan was unjust and outside legal bounds, as proper procedure had not been followed.
Evidence and Testimonies
Testimonies presented during the trial were critical in establishing the facts. The municipal treasurer maintained that Cajuigan never attempted to pay the rent due, while Cajuigan and his witnesses stated that they did attempt to tender the payments. The trial court ultimately found the treasurer's testimony to be more credible, resulting in a determination that Cajuigan had not offered payment as he claimed.
Legal Analysis and Determination
The court analyzed the lease conditions, underlining that failure to pay rent permitted the municipality to rescind the contract and seek penalties. It questioned the validity of the unilateral lease rescission by the municipality without judicial intervention. The court affirmed that the municipality’s forcible eviction constituted unlawful trespass, exposing
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Case Overview
- The case is an appeal from a judgment by the Court of First Instance of Tarlac, presided over by Honorable Julio Llorente.
- It involves the Municipality of Moncada as the plaintiff and Pio Cajuigan along with three sureties as defendants.
- The court condemned the defendants to pay the plaintiff P1,855, along with penalties, interest, and costs.
Contractual Background
- The dispute arose from a lease agreement where the Municipality leased fish ponds to Pio Cajuigan for the term from July 1, 1908, to June 30, 1909, for an agreed payment of P3,710 in quarterly installments.
- Cajuigan began utilizing the leased fish ponds but failed to make the required payments.
- Extensions were granted to Cajuigan for payment deadlines, first until October 1, 1908, and then until November 30, 1908.
Payment Dispute
- On November 30, 1908, Cajuigan claims to have tendered P1,855 to the municipal treasurer, who allegedly refused to accept it, instructing him to return on December 2.
- The plaintiff, the Municipality, denies that any such payment was made.
- The municipal council rescinded the lease on November 30, 1908, after which the Municipality forcibly ejected Cajuigan and his tenants on December 6, 1908.
Legal Proceedings
- A complaint was filed by the Municipality on February 15, 1910, seeking the total amount due under the lease agreement from Cajuigan and the sureties.
- The defendants countered by claiming that the failure to pay was due to the Municipality's refusal to accept payment.
- They