Luna v. Carandang
REITERATIONFacts
The Antecedents: Plaintiff-appellant Mariquita Luna and defendant-appellee Geronimo Carandang entered into a 10-year contract of lease for an agricultural land. The lessee failed to pay the stipulated rent in full for the first two years, accumulating an unpaid rent of P4,156.63 as of March 26, 1964. Procedural History: The lessor commenced an action for rescission with damages in the Court of First Instance (CFI) of Batangas. The CFI granted rescission and damages, including unpaid rents and future rents, but could not order the defendant to vacate the leased premises located in Calapan, Oriental Mindoro, due to its perceived lack of jurisdiction over the property's location. The plaintiff appealed to the Supreme Court on questions of law. The Petition: The plaintiff-appellant contended that the lower court erred in not ordering the defendant-appellee to vacate the leased premises and in not awarding stipulated rents from January 1967 onwards.
Issue(s)
Whether the Court of First Instance of Batangas had jurisdiction to order the defendant-appellee to vacate the leased premises located in Calapan, Oriental Mindoro. Whether the plaintiff-appellant is entitled to stipulated rents of P5,000 yearly from January 1967 up to the time the leased land is returned to the plaintiff.
Ruling
The Supreme Court affirmed the rescission of the contract of lease but modified the judgment. It ordered the appellee to vacate and return the leased premises to the appellant, to pay the unpaid rents from January 1, 1962, to May 26, 1964, with legal interest, and thereafter, to pay P4,500 annually as reasonable rental value until the land is vacated and returned.
Ratio Decidendi
On the issue of jurisdiction to order vacation of premises: The Court held that the CFI of Batangas had jurisdiction. It clarified that while rules on venue require actions involving real property to be brought in the province where the land lies, this is a rule on venue, not jurisdiction, and can be waived. In this case, the defendant's participation in the proceedings without objecting to the venue constituted an implied waiver. Furthermore, rescission of a lease contract inherently requires the return of the leased property, a consequence that the court, having jurisdiction over the rescission case and the parties, could validly order. The stipulation in the contract attempting to confer exclusive jurisdiction on the Court of Batangas was void, as jurisdiction is conferred by law and cannot be subject to contract. On the issue of future stipulated rents: The Court ruled that the plaintiff-appellant was not entitled to the stipulated rent of P5,000 yearly from January 1967 onwards. The Court explained that rescission and performance are incompatible. Ordering payment of future stipulated rents would amount to enforcing the contract, which is contrary to the decree of rescission. However, the Court held that the plaintiff was entitled to the reasonable rental value of the land from the filing of the action for rescission until the property is returned. The Court fixed this reasonable rental value at P4,500 per year, considering the area of the land and the period from May 26, 1964, onwards.
Main Doctrine
A stipulation in a contract conferring exclusive jurisdiction upon a specific court is void as jurisdiction is conferred by law. However, a court may validly exercise jurisdiction over a real property dispute if there is an implied waiver of improper venue by the defendant's failure to object and by participating in the proceedings. Rescission of a lease contract necessitates the return of the leased premises, and the court can order the lessee to vacate and return the property.