Case Summary (G.R. No. 139136)
Background and Nature of the Dispute
The respondents, heirs of the late Virginia Tangga-an, filed an unlawful detainer complaint against the petitioners who were tenants of a residential building. The lease contract, executed with the late Virginia, covered only the use and occupancy of the building, excluding the lot owned by the National Housing Authority (NHA). The petitioners ceased payment of rent from November 1993, accruing P48,000 in arrears by October 1994, and refused to vacate upon repeated demands. The respondents sought to recover possession of the property for their own use.
Petitioners' Defense and Allegations
The petitioners alleged that on July 23, 1993, NHA transferred ownership of the lot to Virgilio and Angelita D. Tangga-an, heirs and relatives of Virginia Tangga-an, asserting that this transfer canceled the lease contract since rightful ownership of the lot (and consequentially the building) had shifted. The petitioners claimed to have paid rent to Virgilio and Angelita thereafter, as the new owners had the legal right to collect rentals.
Municipal Trial Court (MTC) Ruling
The MTC ordered the ejectment of the petitioners and payment of arrears, attorney’s fees, and litigation costs. The court found that the petitioners violated the lease contract by failing to pay rent and did not prove Virgilio owned the house, only the disputed lot. The MTC refused to settle ownership disputes over the lot in the unlawful detainer proceeding, as such issues were pending in separate litigation.
Regional Trial Court (RTC) Affirmation
The RTC upheld the MTC's findings, emphasizing the absence of any modification of the lease contract or proof that Virgilio owned the leased house. The lease agreement remained valid and binding, and the petitioners’ unilateral cessation of rent payment was a clear violation. The court reiterated the principle that contractual obligations carry the force of law and must be complied with in good faith (Article 1159, Civil Code).
Court of Appeals (CA) Decision
The CA found no error in the lower courts’ rulings, confirming that the respondents, as heirs of Virginia, had the right to institute ejectment under Article 487 of the Civil Code. The CA emphasized that ownership of the lot did not ipso facto confer ownership of the building, which belonged to the respondents as heirs through Hermes Tangga-an as trustee. The CA declared the ongoing ownership dispute over the lot irrelevant to the possession issue in unlawful detainer proceedings, citing precedent that such cases involve only possession (de facto) and not title determination.
Issues Raised in the Petition for Review
- Whether the lease covered both the land and the building.
- Whether Virgilio Tangga-an, as heir, had equal rights and could not be excluded by other heirs, affecting the validity of the ejectment suit.
- Whether Virgilio’s Torrens title over the land, including improvements, was indefeasible and immune from collateral attack in the unlawful detainer case.
Supreme Court’s Analysis on Jurisdiction and Ownership
The Court held that Section 16 of the 1997 Revised Rules of Civil Procedure requires the court to resolve ownership issues only as necessary to determine possession in unlawful detainer cases. Here, the petitioners’ defense of ownership was relevant to possession—whether they were excused from paying rent due to change in ownership. Hence, resolution of ownership was permitted to determine rightful possession.
Findings on Lease and Ownership of the Building
The Court found no evidence that Virgilio acquired ownership of the building; his certificate of title pertained only to the lot. The house and lot are distinct immovable properties under Article 415 of the Civil Code and may be separately owned and contracted. Respondents evidenced ownership through tax declarations naming their trustees, which, while not conclusive, are strong indicia of ownership and possession consistent with established jurisprudence.
On Alleged Waiver and Donation of Property
Petitioners claimed Virginia ceded the house and lot to Virgilio before her death. The Court found no proof of consideration or a valid donation complying with formalities required under Articles 749 and 752 of the Civil Code—specifically, the absence of a public instrument and proof the donation did not prejudice forced heirs. Therefore, no valid transfer of ownership of the house was established.
Estoppel and Binding Effect of Lease Contract
The Court underscored that both parties knew at lease execution that the land was owned by the NHA, yet the p
...continue readingCase Syllabus (G.R. No. 139136)
Background and Procedural History
- The case involves a petition for review filed by Spouses Reynaldo and Esmeralda Alcaraz challenging decisions by the Regional Trial Court (RTC) of Cebu City and the Court of Appeals (CA) affirming an ejectment order following a complaint for unlawful detainer.
- Respondents Pedro M. Tangga-an and co-respondents, heirs of the late Virginia Tangga-an, filed complaint against petitioner spouses for unlawful detainer with damages based on the alleged non-payment of rent for a residential building leased to the petitioners.
- The lease contract, executed between petitioners and the late Virginia Tangga-an, covered the residential building only, not the lot which was owned by the National Housing Authority (NHA) at the time.
- Petitioners allegedly stopped paying rent from November 1993 and refused to vacate the premises despite demands.
- Petitioners claimed the lease contract became void following the transfer of ownership of the lot, along with the house, to Virgilio and Angelita D. Tangga-an through NHA’s deed of sale.
- Lower courts ruled for the respondents, ordering ejectment and payment of arrears, upheld by the RTC and the Court of Appeals.
- The case reached the Supreme Court on petitioners’ assignment of errors challenging ownership and legality of ejectment.
Facts of the Case
- Lease contract dated November 22, 1991, between petitioners and Virginia Tangga-an, covered a house only, excluding the lot owned initially by NHA.
- Petitioners stopped paying rent starting November 1993, incurring arrears of P48,000 by October 1994.
- The NHA allegedly transferred ownership of the lot where the house stood to Virgilio and Angelita D. Tangga-an, and Transfer Certificate of Title No. 125657 was issued to Virgilio.
- Petitioners paid rent thereafter to Virgilio and Angelita, asserting extinguishment of the lease due to change in ownership.
- Respondents contended the lease remained valid covering the house, that the house belonged to Virginia’s heirs (respondents), and that ownership of the lot was under litigation.
- The MTC, RTC, and CA found respondents as rightful owners of the leased building and upheld the validity of the lease contract and ejectment.
Issues Presented Before the Supreme Court
- Whether the lease contract included both the land and the residential building or only the latter.
- Whether Virgilio Tangga-an, as heir and registered owner of the lot, h