Case Summary (G.R. No. 141324)
Factual Background
On June 21, 1985, the respondent, Benedicta Martinez, entered into lease agreements with the petitioners, allowing them to occupy portions of the property on a month-to-month basis. These agreements included a provision for termination with three months’ notice. In March and May of 1988, the respondents notified the respective petitioners of their intention to reclaim the land for personal use, thereby effectively terminating the lease agreements. Subsequently, the respondents ceased collecting rent from the petitioners, who nonetheless continued to occupy the property.
Legal Proceedings
On July 18, 1994, the petitioners filed petitions for consignation, depositing their rent with the Metropolitan Trial Court (MeTC) after the respondents initiated unlawful detainer actions against them. The matters were consolidated, and the MeTC ruled in favor of the respondents, ordering the eviction of the petitioners and compensation for the use of the premises, including attorney’s fees.
Trial Court Rulings and Appeals
The Regional Trial Court (RTC) upheld the MeTC decision, which was subsequently affirmed by the Court of Appeals. The petitioners appealed to the Court, reiterating their arguments regarding termination of the lease agreements, withdrawal of tolerance by the respondents, validity of the barangay lupon conciliation, and the award of attorney’s fees.
Jurisdiction and Findings of Fact
The Court reiterated that it does not serve as a trier of facts; hence, the findings of the appellate court, which were consistent with the lower courts, are conclusive. The Court stressed that the lease agreements were validly terminated as of the respective dates of notification in 1988, resulting in legal grounds for ejectment due to expiration of the lease contracts.
Grounds for Ejectment
Under Section 5(f) of Batas Pambansa Blg. 877, the Court clarified that a lease agreement allows for ejectment upon notice if the lessor requires the property for personal use. Given the respondents’ notification to vacate and subsequent actions, the petitioners' failure to leave constituted legal justification for their eviction.
Barangay Conciliation and Compliance
The Court examined the barangay conciliation process under PD 1508, concluding that while it is a procedural requirement, failure to comply did not strip the MeTC of its jurisdiction, especially since the defendants fail
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Case Citation
- 453 Phil. 309
- G.R. No. 141324
- Third Division
- Decision dated July 08, 2003
Parties Involved
- Petitioners: Spouses Virginia Junson and Emilio Junson, Cirila Tan
- Respondents: Spouses Benedicta B. Martinez and Antonio Martinez
Background of the Case
- Respondent spouses are the registered owners of several parcels of land in E. Jacinto Street, Sangandaan, Caloocan City, as evidenced by TCT Nos. C-37014, C-48916, C-39002, and C-37015.
- Petitioners are lessees of portions of these lands, with specific addresses at 117 E. Jacinto Street for the Junsons and 135 E. Jacinto Street for Cirila Tan.
- On June 21, 1985, written agreements allowed petitioners to lease their respective portions on a month-to-month basis with the provision that either party could terminate the lease with three months' notice.
Events Leading to the Dispute
- In March 1988, respondents notified Cirila Tan of their need for her occupied land, providing a three-month notice to vacate.
- A similar notice was sent to the Junsons in May 1988, after which respondents ceased collecting rent from both petitioners.
- Despite these notices, petitioners continued to occupy the properties and paid their rentals through bank deposits to respondent Benedicta Martinez.
Legal Proceedings Initiated
- On July 18, 1994, petitioners filed petitions for consignation in the Metropolitan Trial Court (MeTC) of Caloocan City, depositing their rent with the court.
- Respondents then filed unlawfu