Feraren v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns unlawful detainer. Private respondent Cecilia Tadiar and her co-heirs claim ownership of a 1,200 square meter parcel of land. They allege that their father sold the lot to spouses Antonio and Justina Feraren on pacto de retro in 1960, with a ten-year repurchase period. The co-heirs reacquired the property in 1970. The Spouses Feraren then leased the lot on a month-to-month basis, constructing a residential house. After Antonio Feraren's death, the heirs requested to extend the lease and offered to vacate, but failed to do so, prompting the unlawful detainer suit. 2. Procedural History: Private respondent Cecilia Tadiar filed an unlawful detainer complaint against the Heirs of Antonio Feraren with the Municipal Trial Court (MTC) of San Fernando City, La Union. The MTC dismissed the complaint, finding that the Feraren parents built the house in good faith while they were owners of the lot and thus could not be compelled to vacate without reimbursement. The Regional Trial Court (RTC) affirmed the MTC's decision. Upon review, the Court of Appeals (CA) reversed and set aside the MTC and RTC decisions, ruling that the house was built during the period the Ferarens were lessees and directing the respondents to vacate. The CA denied the petitioners' motion for reconsideration. 3. The Petition: The Heirs of Antonio Feraren filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's decision and resolution. They argue that the CA erred in holding that their house was constructed during the lease and not during the pacto de retro sale period when their parents owned the lot. They also contend that the CA erred in reversing the decisions of the MTC and RTC. Petitioners claim their parents built the current house in the late 1960s when they owned the lot, after demolishing an earlier house built in 1949 when they were lessees.
Issue(s)
Whether the Court of Appeals erred in holding that the petitioners' residential house was constructed during the lifetime of the lease contract and not during the 10-year period when the lot was sold under pacto de retro to the petitioners' parents. Whether the Court of Appeals erred in reversing the decisions of the Regional Trial Court and the Municipal Trial Court.
Ruling
The petition is denied. The assailed Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of the construction period of the house: The Court affirmed the Court of Appeals' finding that the house was constructed when the petitioners' parents were lessees of the lot. This was based on two primary reasons. Firstly, the petitioners' position paper and affidavits were filed beyond the 10-day reglementary period prescribed by the Revised Rule on Summary Procedure and the Rules of Court. The Court emphasized the strict adherence to reglementary periods in summary proceedings to ensure expeditious and inexpensive determination of cases, citing Teraña v. De Sagun. The petitioners' complete disregard for these rules rendered them undeserving of their relaxation. Secondly, the Court found that the petitioners' statement in their Answer, admitting that their parents built the house as lessees under the 1949 lease contract, constituted a judicial admission. Under Section 4, Rule 129 of the Rules of Court, this admission could only be contradicted upon proof of palpable mistake or that no such admission was made, which the petitioners failed to establish. Their subsequent claims in their position paper were deemed a mere afterthought and a contradiction of their prior judicial admission. On the issue of reversing the lower courts' decisions: The Court found no error in the Court of Appeals' ruling. The appellate court correctly disregarded the belatedly filed position paper and affidavits of the petitioners due to their violation of the Revised Rule on Summary Procedure. Moreover, the CA correctly gave weight to the judicial admission made by the petitioners in their Answer, which established that the house was built during the lease period. Consequently, the CA correctly applied Article 1678 of the Civil Code, which governs the rights of a lessee who makes useful improvements. Under this article, if the lessor refuses to appropriate the improvements, the lessee may remove them. Since the private respondent prayed for the demolition of the house, she clearly did not want to appropriate the improvements, thus, the petitioners' sole right was to remove the improvements, not to compel reimbursement of one-half of its value.
Main Doctrine
A belatedly filed position paper and affidavits, submitted beyond the reglementary period prescribed by the Revised Rule on Summary Procedure, should not be admitted and considered by the trial court. Furthermore, a party is bound by a judicial admission made in their Answer unless it is proven to have been made through palpable mistake.