Spouses Fige v. Court Of Appeals
REITERATIONFacts
The Antecedents: Private respondents are the registered co-owners of a parcel of land with improvements, including a store, located at 634 Quirino Avenue, Tambo, Parañaque. In September 1984, one of the co-owners verbally leased the store to petitioners for P700.00 per month. On February 21, 1989, private respondents terminated the lease effective the end of February 1989, giving petitioners 15 days to vacate. Petitioners sent a postal money order for P1,400.00 covering January and February 1989 rentals. Conciliation efforts failed, leading to the filing of an unlawful detainer complaint by private respondents. Procedural History: Petitioners contested the complaint, claiming the lot they occupied was different from the lot described in private respondents' title and that they had purchased it from a third party. The Metropolitan Trial Court (MTC) dismissed the case for lack of cause of action. On appeal, the Regional Trial Court (RTC) reversed the MTC decision, ordering petitioners to vacate and pay rentals and attorney's fees. The Court of Appeals (CA) affirmed the RTC decision with modification, deleting the award of attorney's fees. Petitioners appealed to the Supreme Court. The Petition: Petitioners faulted the CA for disregarding their documentary and testimonial evidence, for failing to consider that the complaint stated no cause of action, and for affirming the RTC decision.
Issue(s)
Whether the respondent Court of Appeals erred in disregarding petitioners' Exhibits and the testimony of Geodetic Engineer Cresencio Supleo. Whether the respondent Court of Appeals erred in its failure to consider that private respondents’ complaint states no cause of action, particularly regarding the landlord-tenant relationship. Whether the respondent Court of Appeals erred in affirming with modification the decision of the Regional Trial Court of Parañaque, especially concerning the evidence presented and the nature of the action for unlawful detainer.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. The petition was denied for lack of merit.
Ratio Decidendi
On the issue of disregarding evidence: The Court held that the documentary evidence presented by petitioners (Exhibits "1", "2" to "2-5", "4", "5", and "6") lacked probative value because they were not verified and approved by the Bureau of Lands as required by law. Exhibit "5" was also inadmissible as it was an uncertified xerox copy and a different document from what was marked in the trial court. The testimony of Engineer Supleo was deemed to have hardly any relevance to the issue of possession. The Court emphasized that for cadastral surveys, it is the duty of private surveyors to submit their work to the Bureau of Lands for verification and approval. On the issue of cause of action and the landlord-tenant relationship: The Court reiterated the well-settled rule that a tenant cannot, in an action involving the possession of the leased premises, controvert the title of his landlord. Furthermore, a tenant cannot set up any inconsistent right to change the existing relation without first delivering up the premises acquired by virtue of the agreement between themselves. The juridical relation between petitioners and private respondents was that of lessee and lessor, and petitioners' claim of purchase from a third party was an attempt to controvert the landlord's title. On the affirmation of the RTC decision: The Court found petitioners' evidence that the lot they occupied was different from the lot described in private respondents' title to be unconvincing. Allegations of fraud and misrepresentation must be proved by clear and convincing evidence, which was not sufficiently established by the petitioners. The Court reiterated that in an action for unlawful detainer, the question of possession is primordial, and the issue of ownership is generally unessential and should be raised in an appropriate action, as a certificate of title cannot be the subject of a collateral attack. The Court was satisfied that private respondents proved their cause of action.
Main Doctrine
A tenant cannot controvert the title of his landlord in an action involving the possession of the leased premises, nor can a tenant set up any inconsistent right to change the existing relation without first surrendering the premises.