Borlongan v. Madrideo
REITERATIONFacts
The Antecedents: Ma. Dalisay Tongko-Camacho owned a parcel of land in Tondo, Manila. A portion of this land, approximately 100 square meters, was the subject of an unlawful detainer case. On this portion stood two houses: one built by Leonardo Borlongan and Dominga Sempio (grandparents of petitioner Clara Borlongan and great-grandparents of petitioners Dina and Percida Borlongan), and another built by private respondent Consuelo Madrideo. Consolacion Sempio, sister of Dominga Sempio, originally leased the lot and lived there with Dominga and Leonardo, their son Hernando, his wife Clara, and their daughters Percida and Dina until Consolacion's death in 1974. Private respondent Madrideo, a ward of Consolacion, built her house on the back portion of the lot in 1961 and paid rentals to Camacho. Procedural History: On May 6, 1993, private respondent Madrideo filed a complaint for unlawful detainer against petitioners Borlongan, alleging that she had allowed them to occupy the portion of the land out of liberality, subject to their vacating upon demand. Petitioners denied this, presenting an affidavit from Camacho stating that petitioners, as heirs of Consolacion Sempio, and private respondent were all her tenants, and that petitioners were not sublessees of private respondent. The Metropolitan Trial Court (MTC) dismissed the complaint, ruling that only the owner, Camacho, could eject petitioners, and that private respondent was not the real party in interest. The Regional Trial Court (RTC) affirmed the MTC decision, finding no evidence of a contract between private respondent and petitioners, and reiterating that private respondent was not the real party in interest. The Court of Appeals (CA) reversed the RTC, holding that private respondent, as the lessee paying rentals for the entire lot, had a better right to possession and could eject petitioners who occupied a portion by mere tolerance and did not pay rent. The CA ordered petitioners to vacate and surrender possession. The Petition: Petitioners filed a petition for review on certiorari with the Supreme Court, assailing the CA's decision and resolution, arguing that the CA erred in allowing a lessee to eject co-lessees and in disregarding the owner's recognition of petitioners as lessees.
Issue(s)
Whether the Court of Appeals erred in reversing the decisions of the Metropolitan Trial Court and the Regional Trial Court. Whether private respondent, as a lessee of a portion of the land, can eject petitioners, who are also lessees recognized by the owner. Whether private respondent is the real party in interest to file an unlawful detainer case against petitioners.
Ruling
The petition is granted. The Decision and Resolution of the Court of Appeals are reversed and set aside. The Decisions of the Regional Trial Court and the Metropolitan Trial Court are reinstated.
Ratio Decidendi
On the issue of the Court of Appeals' reversal of lower court decisions: The Supreme Court found that the findings of fact of the appellate court were "totally devoid of support in the record or that they are so glaringly erroneous as to constitute grave abuse of discretion," thus falling under an exception to the general rule that appellate courts' findings of fact are conclusive. The CA's divergence from the MTC and RTC decisions was based on an interpretation that was not supported by the evidence presented, particularly the affidavit and consistent declarations of the landowner. On the issue of whether private respondent can eject petitioners: The Court held that private respondent, as the plaintiff in the unlawful detainer action, had the burden of proving her allegations by a preponderance of evidence. She failed to meet this burden. Her reliance on rental payment receipts only confirmed her status as a lessee, not the only lessee. The owner, Ma. Dalisay Tongko-Camacho, consistently declared that petitioners were also her lessees. In the face of Camacho's unwavering acknowledgment, private respondent's claim lacked support. The Court found that Camacho, as the owner, was more knowledgeable about the subsisting contracts concerning her land, rendering private respondent's claim unsubstantiated. On the issue of whether private respondent is the real party in interest: The Court agreed with the RTC that private respondent was not the real party in interest. A real party in interest is one who stands to be benefited or injured by the judgment or is entitled to the avails of the suit. Private respondent failed to establish her claim of being the sole lessee or the sublessor of the petitioners. Since she did not have a legal right or interest to protect concerning the possession of the disputed property, she could not invoke the court's jurisdiction as a plaintiff. Therefore, the dismissal of the case for lack of cause of action by the MTC, as affirmed by the RTC, was proper.
Main Doctrine
A lessee who claims to be a sublessor and seeks to eject occupants by mere tolerance must establish her claim by preponderance of evidence. If the owner of the property unequivocally declares that the occupants are also lessees, the lessee's claim lacks buoyancy, and she is not the real party in interest to file an unlawful detainer case.