Delicano v. Pechaten Corp.
G.R. No. 191251 (September 7, 2011)
Facts:
Respondent Pechaten Corporation is the registered owner of a parcel of land located at 852 Vicente Cruz Street, Sampaloc, Manila, covered by Transfer Certificate of Title No. 95052. In June 1993, Pechaten Corporation entered into a two-year lease contract with Teodoro Alberto, Honorata Salmorin, Aquilina Hizon, and Dalmacia Meneses, stipulating a monthly rental of P864 for the first year and P1,037 for the second year. After the lease expired on June 30, 1995, the lessees, particularly Virgilio Meneses (son of Dalmacia Meneses), failed to renew the lease or pay rent, prompting Pechaten Corporation to send a demand letter on October 6, 1999, for the lessees to vacate the property and pay accrued rent amounting to P141,032.
When Virgilio Meneses refused to vacate, Pechaten Corporation filed an unlawful detainer case against him in the Metropolitan Trial Court (MeTC). Meneses contended that the MeTC lacked jurisdiction as the case was filed more than four years after the lease expired, arguing that the appropriate remedy was accion publiciana. He also claimed he was not a party to the lease contract, thus Pechaten Corporation had no cause of action against him.
On February 12, 2002, the MeTC ruled in favor of Pechaten Corporation, ordering Meneses to vacate the premises and pay reasonable compensation for its use. This decision was affirmed by the Regional Trial Court (RTC) on May 30, 2008, which held that the one-year period for filing the unlawful detainer suit should be counted from the last demand made on October 6, 1999.
Subsequently, the City of Manila filed an expropriation case against Pechaten Corporation concerning the same property, which resulted in a Writ of Possession being issued in favor of the City. After the death of Virgilio Meneses, his heirs (the petitioners) sought to dismiss the unlawful detainer case, arguing it was rendered moot by the expropriation proceedings. Pechaten Corporation opposed this, asserting that the expropriation order was under appeal.
On August 27, 2008, the RTC partially reconsidered its earlier decision, setting aside the order for Meneses to vacate the property, citing the expropriation case as moot. Pechaten Corporation appealed this decision to the Court of Appeals, which initially affirmed the RTC's ruling on February 18, 2009. However, after a subsequent decision in the expropriation case dismissed the City of Manila's complaint, Pechaten Corporation filed a motion for reconsideration, which led to the Court of Appeals amending its decision on November 13, 2009, in favor of Pechaten Corporation.
Legal Issues:
The primary legal issue in this case is whether the petitioners (heirs of Virgilio Meneses) are entitled to retain possession of the property despite the dismissal of the expropriation case, which had previously granted possession to the City of Manila.
Arguments:
Petitioners' Argument: The petitioners contended that the unlawful detainer case was rendered moot by the Writ of Possession issued in the expropriation case. They argued that since the City of Manila had taken possession of the property, they should be allowed to retain it, especially after the City had turned over the property to them.
Respondent's Argument: Pechaten Corporation argued that the dismissal of the expropriation case constituted a supervening event that warranted the restoration of its possession of the property. They maintained that the RTC's decision to set aside the order for the petitioners to vacate was erroneous, as the title to the property remained with Pechaten Corporation.
Court's Decision and Legal Reasoning:
The Supreme Court found the petition without merit, affirming the Court of Appeals' Amended Decision. The Court held that the dismissal of the expropriation case was indeed a supervening event that justified the reconsideration of the earlier rulings. It emphasized that under Section 11, Rule 67 of the Rules of Civil Procedure, if an appellate court determines that the plaintiff has no right to expropriate, the defendant must be restored to possession of the property.
The Court noted that the expropriation was found not to be for public use, and since the decision dismissing the expropriation case became final and executory, Pechaten Corporation was entitled to regain possession of the property. The Court reiterated that despite the Writ of Possession previously issued, the legal title to the property remained with Pechaten Corporation, and thus, possession must revert back to the rightful owner.
Significant Legal Principles Established:
Supervening Events: The Court recognized that a supervening event, such as a final and executory decision in a related case, can warrant the reconsideration of prior rulings.
Restoration of Possession: The ruling reinforced the principle that if an expropriation is found to be invalid, the original owner must be restored to possession of the property.
Jurisdiction in Unlawful Detainer Cases: The case highlighted the importance of timely filing in unlawful detainer actions, emphasizing that the one-year period for filing such cases is counted from the last demand for possession.