Case Summary (G.R. No. L-49852)
Key Dates
• September 16, 1976 – Respondent filed unlawful detainer action in the Municipal Court of Navotas.
• September 20, 1977 – Municipal Court rendered judgment for respondent.
• May 18, 1978 – Court of First Instance of Rizal affirmed lower court judgment.
• August 29, 1978 – Court of Appeals denied petitioner’s appeal by certiorari.
• January 16, 1979 – Court of Appeals denied motion for reconsideration.
• October 19, 1989 – Supreme Court promulgated decision on certiorari review.
Applicable Law
• Unlawful Detainer (Rule 70, Rules of Court) – lessor may recover possession after demand for unpaid rent.
• Civil Code provisions on lease (Arts. 1642–1677) and judicial deposit (Art. 1256).
• Mora Accipiendi – default by landlord in accepting rent.
• Laches – delay in asserting legal right.
Factual Background
- Respondent leased to petitioner a ground-floor portion of his property for monthly rent.
- Petitioner ceased paying rent in February 1974, allegedly because the collector, a family member, stopped calling.
- Respondent first demanded surrender and payment on August 23, 1976; suit filed September 16, 1976.
- Petitioner contested ownership, asserted lease was with respondent’s mother, and alleged refusal of the collector to accept tendered rent.
Issues Presented
- Whether respondent established ownership of the leased premises.
- Whether petitioner validly tendered unpaid rentals and landlord committed mora accipiendi.
- Whether laches barred respondent’s action.
- Whether respondent proved cause of action for unlawful detainer.
Lower Courts’ Findings
• Ownership – trial court found respondent held a Certificate of Title to the lot; appellate courts deferred to this factual determination.
• Tender and Mora Accipiendi – courts held that petitioner’s offer of payment to an unauthorized collector did not discharge her obligation and that judicial deposit should have been made.
• Laches – the wrongful detainer action was timely because demand and filing occurred within months of respondent’s assertion of his rights after allowing continued occupancy.
• Cause of Action – respondent established a demand for unpaid rent and petitioner’s refusal to vacate, satisfying unlawful detainer requisites.
Court of Appeals’ Reasoning
- Ownership: Tenant cannot deny landlord’s title at the inception of the lease; findings supported by substantial evidence.
- Tender of Rent: Petitioner failed to deposit unpaid rentals in court; unauthorized recipient’s refusal did not excuse payment.
- Laches: A landlord may extend credit and refrain from suing; legal possession becomes unlawful only after formal demand and refusal following default.
- Applicable Statutes: Commonwealth Act No. 53 (prima facie evidence of unwritten contracts) inapplicable because lease terms were neither disputed nor in an unknown language.
Supreme Court Analysis
• Fact-Finding Deference: Affirmed trial court’s factual determinations on ownership and nonpayment absent proof of overlooked evidence.
• Mora A
Case Syllabus (G.R. No. L-49852)
Facts of the Case
- The private respondent, Benjamin Cifra, Jr., claimed ownership of the premises at No. 164 Int., Gov. Pascual Street, Navotas, Metro Manila, and had leased the same to Emilia Tengco.
- Tengco allegedly defaulted in the payment of stipulated rentals despite repeated demands.
- On September 16, 1976, Cifra filed an unlawful detainer action (Civil Case No. 2092) in the Municipal Court of Navotas to recover possession and collect arrears in rentals.
- At trial, the Municipal Court rendered judgment ordering Tengco to vacate the premises, to pay P376.00 as arrears plus P12.00 per month from October 1976 until full vacation, and to pay P200.00 for attorney’s fees and costs.
Procedural History
- September 20, 1977: Municipal Court of Navotas rendered judgment in favor of the plaintiff (Cifra) and against the defendant (Tengco).
- May 18, 1978: Court of First Instance of Rizal (Civil Case No. C-6625) affirmed the Municipal Court’s decision in toto, without pronouncement as to costs.
- August 29, 1978: Court of Appeals (CA-G.R. No. SP-08182) denied Tengco’s “Appeal by Way of Certiorari,” dismissing it outright for lack of merit.
- January 16, 1979: Court of Appeals denied Tengco’s motion for reconsideration.
- October 19, 1989: Supreme Court promulgated the present decision on certiorari.
Issues Presented
- Whether Benjamin Cifra, Jr. is the true owner of the leased premises.
- Whether the lessor committed mora accipiendi (delay in accepting payment).
- Whether the tenant’s version of events is more credible than the landlord’s.
- Whether laches barred the less