Manuel v. De Jesus
REITERATIONFacts
The Antecedents: This case originated from a complaint for ejectment filed by private respondents, Spouses Jesus and Carmen de Jesus, against petitioner Agapito Manuel. The dispute centered on petitioner's failure to pay monthly rentals for an apartment unit owned by the private respondents. The rentals, amounting to P466.00 per month, were due in advance, and petitioner had failed to pay from May 1987 up to the filing of the complaint on August 31, 1987. Private respondents had sent a demand letter on July 9, 1987, requiring payment and vacation of the premises within five days of receipt, which petitioner received on July 14, 1987. Procedural History: The ejectment case was initially filed before the Metropolitan Trial Court (MTC) of Manila, which ruled in favor of the private respondents on April 6, 1989, ordering petitioner to vacate, pay rentals in arrears, and reimburse attorney's fees and costs. Petitioner appealed to the Regional Trial Court (RTC) of Manila, Branch 35, which affirmed the MTC's decision in its entirety on September 20, 1989. Subsequently, petitioner elevated the case to the Court of Appeals (CA) via a petition for review. The CA, in its decision dated January 29, 1990, denied due course to the petition and dismissed it for lack of merit. A motion for reconsideration filed by the petitioner was also denied by the CA in its resolution of March 5, 1990. The Petition: Petitioner seeks review of the Court of Appeals' decision before the Supreme Court, raising two grounds. The primary ground posits a supervening event: the National Housing Authority (NHA) allegedly awarded the lot on which the apartment stands to petitioner and other tenants, disqualifying the private respondents. Petitioner argues this award makes ejectment unjust and impossible, and that private respondents were in mora accipiendi (delay in acceptance) regarding rentals, which was rendered moot by the NHA award and public policy favoring occupants. The second ground reiterates the mora accipiendi argument, asserting that petitioner continuously made rentals available and deposited them, and that the private respondents' refusal to accept rendered their cause of action moot. Petitioner contends that the NHA award signifies a shift in ownership and public policy that should protect his possession.
Issue(s)
Whether a supervening award of the lot by the NHA to the petitioner renders the ejectment case unjust and impossible, and whether the issue of ownership can be raised in an ejectment case. Whether private respondents were in mora accipiendi and if petitioner's alleged deposit of rentals constituted valid payment or consignation.
Ruling
The petition is denied, and the assailed decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of the NHA award, ownership, and raising ownership in ejectment: The Court held that the putative award by the NHA to the petitioner of the lot where the rented apartment stands, while the ejectment case was pending, is of no moment. The juridical relation between petitioner and private respondents as lessee and lessors was well-established, and the non-payment of rentals for at least three months was substantially proven. The award of the lot to the petitioner does not automatically vest ownership over the leased structure. A tenant cannot controvert the title of his landlord or assert rights adverse to it without first surrendering the premises. Proceedings in ejectment are summary, focusing on the fact of lease and expiration of terms, not ownership. Any controversy over ownership should be settled in a separate, appropriate action after possession is returned to the party with prior peaceful possession. The principle of respect for possessory status is temporary and for the maintenance of public order, not for adjudicating ownership in an ejectment case. The Court reiterated that in ejectment cases, the question of ownership is unessential and should be raised in an appropriate action. An ejectment action lies even against the owner of the property, as the fact of possession itself has a distinct legal standing. The protection afforded to possession is temporary and for the maintenance of public order, pending resolution of ownership in a proper court and action. The juridical relation of lessor and lessee, once established in an unlawful detainer case, precludes the defendant from injecting the question of ownership, except as it might illuminate the right of possession. On the issue of mora accipiendi and consignation: The Court found that the contention of petitioner that private respondents were in mora accipiendi cannot be upheld. The failure or refusal of owners to collect rentals is not a valid defense without proper consignation. Consignation, under the law, requires strict compliance with specific legal requirements. Section 5(b) of Batas Pambansa Blg. 25, as amended, mandates that in case of refusal by the lessor to accept rent, the lessee shall deposit the amount by way of consignation in court or in a bank in the name of and with notice to the lessor. Petitioner's failure to comply with this requirement made the consignation defective, thus giving rise to a cause of action for ejectment. Substantial compliance is not sufficient; compliance must be full and strict.
Main Doctrine
A tenant cannot, in an action involving the possession of the leased premises, controvert the title of his landlord or assert any rights adverse to that title or set up any inconsistent right to change the relation existing between himself and his landlord, without first delivering up to the landlord the premises acquired by virtue of the agreement between themselves. Proceedings in forcible entry and detainer are wholly summary in nature; the fact of lease and the expiration of its terms are the only elements of this kind of action. Any controversy over ownership rights could and should be settled after the party who had the prior, peaceful and actual possession is returned to the property. Failure to comply with the requisites of a valid consignation, particularly the requirement of deposit by way of consignation in court or in a bank in the name of and with notice to the lessor, renders the consignation defective and gives rise to a cause of action for ejectment.