Sy Oh v. Garcia* and *Lim Chi v. Garcia
REITERATIONFacts
The Antecedents: Petitioners Sy Oh and Lim Chi were lessees of the Arias Building under verbal contracts of lease. The owner, private respondent Pivgeth Industries & Development Corp., sent them letters of demand to vacate. Procedural History: Ejectment suits were filed on July 21, 1967. Petitioners moved to dismiss, alleging the one-year period had lapsed since the first demand dated April 27, 1964. The respondent Judge denied the motions, finding the suits timely based on the last letters of demand dated September 30, 1966 (Sy Oh) and September 29, 1966 (Lim Chi). The Petition: Petitioners assailed the denial of their motions to dismiss via petitions for certiorari with the Court of First Instance, which were also denied. They then appealed to the Supreme Court.
Issue(s)
Whether the one-year period in unlawful detainer suits should be counted from the first demand letter or the last demand letter sent to the lessee.
Ruling
The Supreme Court affirmed the decisions of the lower courts, upholding the jurisdiction of the respondent City Court Judge. The appeals were dismissed for lack of merit.
Ratio Decidendi
On Issue 1: The Supreme Court held that the one-year period in ejectment suits is to be reckoned from the date of the last demand letter sent to the lessee. This ruling follows the established principle in Racaza v. Susana Realty, Inc., which states that a lessor has the right to waive his action based on the first demand and allow the lessee to remain in the premises. The Court further cited Calubayan v. Pascual, affirming that the length of time a defendant detains the premises is calculated from the date of the last demand. This view has been consistently upheld by the Court since the 1913 case of Lucido v. Vita. The Court emphasized that allowing the period to be counted from the first demand would create a technicality that defeats the summary nature of unlawful detainer actions. Consequently, since the suits were filed within one year of the September 1966 demands, the City Court of Manila properly exercised jurisdiction.
Main Doctrine
In ejectment suits, the one-year period for filing the action is reckoned from the date of the last letter of demand, not the first.