Santos v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondent Philippine Geriatrics Foundation, Inc. (PGFI) occupied a ground floor space in the Geriatrics Center in 1969 and later built an adjacent gymnasium, which was converted into a canteen. Petitioner Ligaya S. Santos occupied this canteen in 1989 through a letter-contract with PGFI's president. PGFI was later asked to vacate its main office and planned to transfer to the canteen. PGFI demanded petitioner vacate in December 1993, citing termination of the lease, but petitioner refused. PGFI was forcibly ejected from its main office in January 1995 and sent another demand letter to petitioner for unpaid rentals and to vacate, which was again ignored. Procedural History: PGFI filed an ejectment case against petitioner, seeking unpaid rentals. The Metropolitan Trial Court (MeTC) dismissed the complaint, finding no evidence of a lease contract, as PGFI's claimed original contract was lost and an unsigned photocopy was refused as secondary evidence. The Regional Trial Court (RTC) affirmed the MeTC decision. PGFI moved for reconsideration and then for a new trial, presenting the original signed lease contract found after the trial. The RTC denied the motion for new trial, deeming the contract "forgotten evidence." The Court of Appeals (CA) reversed the RTC, holding the unsigned copy admissible as secondary evidence and that PGFI proved the contract's existence and contents through affidavits and the unsigned copy. The CA ordered petitioner to vacate and pay rentals. The Petition: Petitioner seeks reversal of the CA decision, arguing the CA erred in holding that a lease contract was established, in admitting the newly found original contract as it was not formally offered, and in reversing the RTC decision which had allegedly become final.
Issue(s)
Whether the Court of Appeals erred in holding that the respondent was able to establish the fact of the execution of the letter-contract of lease. Whether the Court of Appeals erred when it admitted as newly found evidence the allegedly signed letter-contract of lease even though the same was not formally offered in evidence during trial. Whether the Court of Appeals erred in setting aside the decision of the Regional Trial Court affirming the decision of the Metropolitan Trial Court which dismissed the complaint.
Ruling
The petition is denied. The decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of establishing the lease contract: The Court held that the existence and due execution of the lease contract were established by the affidavits of PGFI's trustees who were signatories thereto. The loss of the original contract was also proven through the affidavit of Vicente Pulido, who attested to its keeping at the PGFI office and its loss during the chaotic eviction. Consequently, secondary evidence, such as the unsigned photocopy and testimonial evidence, was admissible to prove the contract's contents as per Rule 130, Section 5 of the Rules of Court. The Court noted that petitioner did not object to the genuineness of the original contract when it was later found, indicating its authenticity. On the admissibility of the newly found original contract: The Court found that PGFI's motion to treat its motion for reconsideration as a motion for new trial on the ground of newly discovered evidence was procedurally proper. The filing of such motions suspends the period to appeal, and the petition for review before the CA was filed within the granted extension. Therefore, the RTC decision had not yet become final. The Court also noted that the original contract, when found, merely affirmed what had already been established by secondary evidence, and petitioner's lack of objection to its genuineness further supported its admissibility. On the propriety of the CA's reversal of the RTC decision: The Court agreed with the CA that a valid lease agreement existed between the parties. Petitioner's obligation to pay monthly rentals was established. Although the original lease period expired in December 1991, the lease was impliedly renewed on a month-to-month basis under Article 1670, in relation to Article 1687, of the Civil Code, as petitioner continued occupying the premises. Petitioner's failure to pay rentals after December 1993 constituted a violation of the lease agreement, justifying ejectment under Article 1673 of the Civil Code. Thus, the CA did not err in reversing the RTC's dismissal of the complaint.
Main Doctrine
The existence and due execution of a lost lease contract can be proven by secondary evidence, including affidavits of signatories and an unsigned copy, provided the loss is not due to bad faith. Failure to pay rentals under an impliedly renewed lease justifies ejectment.