Tan Siok Kuan v. Ho
REITERATIONFacts
The Antecedents: Petitioners Tan Siu Kuan and Pute Ching filed seven (7) separate unlawful detainer complaints against respondents Felicisimo "Boy" Ho, Rodolfo C. Returta, Vicente M. Salas, and Lolita Malonzo, along with other defendants. Petitioners claimed ownership of the property located at Apollo Street, San Francisco del Monte, Quezon City, evidenced by Transfer Certificate of Title (TCT) Nos. 279014 and 279015. They asserted that the respondents had been leasing portions of this property since 1972 and had failed to pay rentals, prompting a written demand on February 7, 2003, for them to pay or vacate. The respondents, however, denied any lessor-lessee relationship, claiming to have possessed the property since 1966 or 1968, built their homes thereon, and never paid rent to the petitioners. They also questioned the authenticity of the petitioners' titles. Procedural History: The Metropolitan Trial Court (MeTC) ruled in favor of the petitioners, finding an implied admission of lease agreements by some defendants and giving weight to the petitioners' registered titles against the respondents' denials. The Regional Trial Court (RTC) affirmed the MeTC's decision. Subsequently, a Writ of Execution was issued, and the premises were turned over to the petitioners. However, the Court of Appeals (CA) reversed the RTC's decision, dismissing the unlawful detainer complaints for lack of merit. The CA agreed with the respondents that the petitioners failed to adequately prove their right as lessors and upheld the respondents' invocation of the principle of res inter alios acta, finding that the alleged admissions of other defendants did not bind the respondents. The Petition: Petitioners filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's decision. They raised two main issues: first, that the CA erred in not holding that the RTC decision had become final and executory due to the respondents' failure to file their motion for reconsideration within the reglementary period; and second, that a lessor-lessee relationship between the petitioners and respondents was properly established. The Supreme Court, however, found that the respondents' motion for reconsideration was timely filed and that the petitioners failed to present sufficient evidence to establish a lessor-lessee relationship, thus affirming the CA's dismissal of the unlawful detainer complaints.
Issue(s)
Whether the RTC Decision had become final and executory due to the respondents' alleged failure to file a timely motion for reconsideration. Whether a lessor-lessee relationship between the petitioners and respondents was properly established.
Ruling
The Supreme Court denied the petition, affirming the Court of Appeals' Decision. The unlawful detainer cases filed by the petitioners against the respondents were dismissed for lack of merit.
Ratio Decidendi
On the issue of the timeliness of the Motion for Reconsideration: The Court found that the respondents' motion for reconsideration was timely filed. While the respondents' motion initially stated receipt of the RTC Decision on May 15, 2005, they clarified that this was an inadvertent error. The records showed that the RTC Decision was mailed on June 7, 2005, and respondents received it on June 15, 2005. Therefore, their motion for reconsideration filed on June 29, 2005, was within the reglementary period, and the RTC Decision had not yet become final and executory. On the issue of the establishment of a lessor-lessee relationship: The Court ruled that the petitioners failed to establish a lessor-lessee relationship with the respondents. The petitioners' claims were unsubstantiated by evidence, lacking details on how and when the alleged lease began, and failing to present proof of prior rental payments or demands, despite alleging non-payment since 1997 and filing the case in 2003. The Court also found merit in the respondents' invocation of the principle of res inter alios acta. The alleged implied admission of a lessor-lessee relationship by other defendants could not be used against the respondents, who consistently denied any lease contract with the petitioners from the outset. The defenses espoused by the respondents were distinct from those of the other defendants, and the principle dictates that a party cannot be prejudiced by the acts or declarations of strangers, absent any recognized exceptions.
Main Doctrine
The principle of res inter alios acta precludes the admission of evidence of acts or declarations of a party as binding upon another party, unless the latter falls under the exceptions provided by law. In unlawful detainer cases, the alleged implied admission of a lessor-lessee relationship by other defendants cannot be used against defendants who consistently denied such relationship.