Fairland Knitcraft Corp. v. Po
REITERATIONFacts
The Antecedents: Petitioner Fairland Knitcraft Corporation (Fairland) filed an unlawful detainer case against respondent Arturo Loo Po (Po) for non-payment of rent for Condominium Unit No. 205. Fairland alleged that it owned the unit and had leased it to Po under a verbal agreement with a monthly rent of P20,000.00. Po allegedly failed to pay rent from March 2011. Fairland sent a demand letter on January 30, 2012, demanding payment of P220,000.00 in arrears and vacation of the premises within 15 days. Po failed to comply. Procedural History: Fairland filed the unlawful detainer complaint on December 12, 2012. Po failed to file an answer within the reglementary period. Fairland filed a motion to render judgment. Po filed a belated Entry of Appearance with Motion for Leave to file Comment/Opposition, denying the allegations and raising issues of ownership and jurisdiction. The Metropolitan Trial Court (MeTC) treated Po's comment as an answer but denied the motion for being out of time. The MeTC dismissed the complaint for failure to prove its case by preponderance of evidence. The Regional Trial Court (RTC) affirmed the MeTC's decision. The Court of Appeals (CA) also dismissed Fairland's petition, ruling that an unlawful detainer action would not lie due to Fairland's failure to prove its ownership. Fairland filed a motion for reconsideration, attaching its condominium certificate of title, but it was denied. The Petition: Fairland filed a petition for review on certiorari before the Supreme Court, arguing that in ejectment cases where no answer is filed, judgment should be based on the facts alleged in the complaint, not on preponderance of evidence, and that attaching evidence to the complaint is not required.
Issue(s)
Whether the MeTC correctly dismissed the unlawful detainer case for failure to prove its case by preponderance of evidence despite the respondent's failure to file an answer. Whether the attachment of documentary evidence to the complaint is mandatory in an unlawful detainer case governed by summary procedure.
Ruling
The petition is granted. The Court reversed and set aside the decisions of the Court of Appeals, Regional Trial Court, and Metropolitan Trial Court. Respondent Arturo Loo Po is ordered to vacate Condominium Unit No. 205 and to pay rentals in arrears and accruing rentals until he vacates the property, with legal interest.
Ratio Decidendi
On the issue of whether the MeTC correctly dismissed the unlawful detainer case for failure to prove its case by preponderance of evidence despite the respondent's failure to file an answer: The Court ruled that the MeTC erred in dismissing the case for lack of preponderance of evidence. Under Section 6 of the Rules on Summary Procedure, if a defendant fails to file an answer, the court shall render judgment as may be warranted by the facts alleged in the complaint and limited to what is prayed for therein. The failure to file an answer constitutes an admission of all the allegations in the complaint. Therefore, the court should have rendered judgment based on the allegations in Fairland's complaint, which sufficiently alleged a cause of action for unlawful detainer, including the ownership of the property, the lease agreement, the non-payment of rent, and the demand to vacate. The lower courts' requirement for proof of preponderance of evidence was contrary to the Rules on Summary Procedure. On the issue of whether the attachment of documentary evidence to the complaint is mandatory in an unlawful detainer case governed by summary procedure: The Court held that the attachment of documentary evidence to the complaint is not mandatory, especially when the complaint sufficiently alleges a cause of action. The Rules on Summary Procedure do not require the plaintiff to attach evidence to the complaint at the initial stage. The purpose of examining attached documents is to ascertain the sufficiency of the allegations, not their veracity. Furthermore, in cases where no answer is filed, the court renders judgment based on the facts alleged in the complaint, making the presentation of evidence at that stage unnecessary. The Judicial Affidavit Rule, which requires the submission of affidavits and exhibits, is also not applicable in cases where no answer is filed, as there would be no pre-trial, preliminary conference, or hearing.
Main Doctrine
In cases governed by the Rules on Summary Procedure, where a defendant fails to file an answer, the court shall render judgment based solely on the facts alleged in the complaint and limited to what is prayed for therein, without requiring proof of preponderance of evidence.