Case Summary (G.R. No. L-49852)
Background of the Case
- Emilia Tengco, the petitioner, was involved in a legal dispute with Benjamin Cifra, Jr., the private respondent, regarding a lease agreement for a property located at No. 164 Int., Gov. Pascual St., Navotas, Metro Manila.
- Cifra filed an action for unlawful detainer against Tengco in the Municipal Court of Navotas, claiming she failed to pay rent despite repeated demands.
- The Municipal Court ruled in favor of Cifra, ordering Tengco to vacate the premises and pay arrears in rent and attorney's fees.
Proceedings in Lower Courts
- Tengco appealed the Municipal Court's decision to the Court of First Instance of Rizal, which affirmed the lower court's ruling.
- Tengco subsequently filed an "Appeal by Way of Certiorari" with the Court of Appeals, which also dismissed her appeal, finding the lower courts' decisions supported by substantial evidence.
Petitioner’s Arguments
- Tengco contended that the Court of Appeals erred in upholding the lower court decisions, asserting several points:
- Cifra was not the legitimate owner of the leased premises.
- The lessor was guilty of mora accipiendi (delay in accepting payment).
- Her version of events was more credible than Cifra's.
- Laches had barred Cifra from ejecting her.
- Cifra failed to establish a valid cause of action against her.
Court of Appeals' Rationale
- The Court of Appeals addressed Tengco's claims, emphasizing that:
- Ownership of the property was a factual issue, and the trial court's findings were entitled to deference.
- Tengco admitted to being a lessee and acknowledged her default in rental payments.
- The claim of refusal to accept payment was insufficient to negate her obligation to pay rent.
- The demand for payment and subsequent filing of the complaint were timely, negating the laches defense.
Findings on Ownership and Lease Agreement
- The appellate court found that the question of ownership was factual and supported by the trial court's findings.
- Tengco's argument regarding the lease agreement being with Cifra's mother was dismissed, as the trial court's determination of Cifra as the lessor was upheld.
- The court noted that a tenant cannot deny the title of the landlord at the commencement of the landlord-tenant relationship.
Analysis of Mora Accipiendi
- Tengco's claim of mora accipiendi was rejected, as the refusal to accept payment was justified due to the transfer of ownership to Cifra.
- The court highlighted that the lease agreement was verbal and unrecorded, thus ceasing to have effect upon the sale of the property.