Spouses Junson v. Spouses Martinez
REITERATIONFacts
The Antecedents: Respondent spouses Martinez are the registered owners of several parcels of land. Petitioners spouses Junson and Cirila Tan were lessees of portions of these lands where they erected their houses. On June 21, 1985, written agreements allowed petitioners to continue leasing on a month-to-month basis, terminable upon three months' notice. Procedural History: In March and May 1988, respondents notified petitioners Tan and Junson, respectively, to vacate the property for the respondents' own use, ceasing to collect rentals. Petitioners failed to vacate and instead deposited rentals in a bank. Petitioners filed consignation cases, and respondents filed unlawful detainer cases after barangay conciliation failed. The Metropolitan Trial Court (MeTC) dismissed the consignation cases and ruled in favor of respondents in the ejectment cases, ordering petitioners to vacate and pay compensation and attorney's fees. The Regional Trial Court (RTC) affirmed the MeTC decision. The Court of Appeals denied petitioners' appeal, affirming the RTC's decision. The Petition: Petitioners seek review of the Court of Appeals' decision, raising issues regarding the termination of lease contracts, the withdrawal of tolerance, the validity of the certification to file action and compliance with barangay conciliation, and the order to vacate and pay attorney's fees.
Issue(s)
Whether the RTC erred in finding that the petitioners' lease contracts were terminated on or about May 1988, transforming their occupancy to one of tolerance. Whether the RTC erred in finding that private respondents withdrew their tolerance by letters dated July 26, 1994. Whether the RTC erred in finding that private respondents' certification to file action is valid and that their complaints complied with the prescribed barangay lupon conciliation procedure. Whether the RTC erred in ordering petitioners to vacate the premises and to pay attorney's fees.
Ruling
The petition is DENIED. The decision of the Court of Appeals affirming the RTC's ruling is upheld.
Ratio Decidendi
On the termination of lease contracts and transformation of occupancy to tolerance: The Court held that a lease on a month-to-month basis is a lease with a definite period. The expiration of this period, upon previous demand by the lessor to vacate, can justify ejectment. In this case, notices to vacate were sent in March 1988 and May 1988, respectively, to petitioners Tan and the Junsons. Therefore, the lease agreements were validly terminated as of March 1988 (for Tan) and May 1988 (for the Junsons). As of these dates, sufficient cause for ejectment arose under Section 5(f) of Batas Pambansa Blg. 877, which allows ejectment upon expiration of the lease contract. Furthermore, if the lessor needs the property for their own use, the lease is considered terminated at the end of the month following proper notice to vacate. Thus, the ejectment of petitioners was justified. On the withdrawal of tolerance by letters dated July 26, 1994: The Court noted that the Supreme Court is not a trier of facts and its jurisdiction is limited to reviewing errors of law. The appellate court's findings of fact are conclusive, especially when they affirm the findings of the trial courts. The Court of Appeals adopted the findings of fact of the trial courts, which included the finding that tolerance was withdrawn. Therefore, this factual finding is binding on the Supreme Court. On the validity of the certification to file action and barangay conciliation procedure: The Court reiterated that the conciliation procedure required under PD 1508 is not a jurisdictional requirement. Failure to have prior recourse to it does not deprive a court of its jurisdiction. Non-compliance does not prevent a court from exercising its adjudicatory power if the defendants fail to object to such exercise of jurisdiction. Such objection must be seasonably made, preferably in the Answer or other responsive pleading. Since the petitioners did not timely object to the lack of prior barangay conciliation, they are deemed to have waived this procedural defect. On the order to vacate and pay attorney's fees: The Court found the award of attorney's fees in the amount of P5,000.00 to be reasonable. This award is sanctioned by Article 2208 of the Civil Code, specifically paragraph (2), which allows recovery of attorney's fees when the defendant's act or omission has compelled the plaintiff to litigate or incur expenses to protect their interest. The petitioners' unjustifiable and unlawful retention of the premises forced the respondents to undergo unnecessary trouble and expense to protect their property rights. The Court also observed that the petitioners and their counsel engaged in maneuvers to delay the disposition of the ejectment cases and warned the counsel of serious sanctions.
Main Doctrine
A month-to-month lease is considered a lease with a definite period, and its expiration, upon proper notice to vacate by the lessor, justifies ejectment. Failure to comply with barangay conciliation procedures is not a jurisdictional defect if not timely objected to.