Guanzon v. Ang
REITERATIONFacts
The Antecedents: The underlying dispute concerns a lease agreement entered into on February 24, 1941, between Epifiana Vda. de Guanzon and defendant Tan Kue for property located at Nos. 1008 and 1010 Lavezares, Binondo, Manila. The lease was for a monthly rental of P130, effective from March 15, 1941, to March 15, 1946. Tan Kue abandoned the property in December 1944, failing to pay rent from January 1945. Subsequently, defendants Ang Ban and Ang Chung occupied the premises without legal grounds, leading to the initial ejectment complaint. Procedural History: The original complaint for ejectment was filed on April 28, 1945, against Ang Ban and Ang Chung. Tan Kue was later included as a defendant through amended pleadings. The Court of First Instance of Manila, presided over by Judge Mariano L. de la Rosa, rendered a decision terminating the lease contract, ordering the defendants to vacate the premises, and to jointly and severally pay P130 per month from January 1945 until the property was vacated, along with costs. The case reached the Supreme Court on appeal by the defendants. The Petition: The defendants appealed the decision of the lower court, alleging two primary errors: (1) the failure to dismiss the complaint due to the plaintiff's non-compliance with the notice requirement under Section 2 of Rule 72 of the Rules of Court, and (2) the failure to declare that Tan Kue's non-payment of rent was due to force majeure. The Supreme Court, however, found Section 2 of Rule 72 inapplicable to both Tan Kue and the other defendants, and deemed the force majeure argument irrelevant to the obligation to pay rent.
Issue(s)
Whether Section 2 of Rule 72 of the Rules of Court is applicable to the defendants. Whether Tan Kue's failure to pay rents constituted force majeure, excusing his obligation. Whether Tan Kue is liable for rents from January 1945 until the premises are vacated by Ang Ban and Ang Chung.
Ruling
The Supreme Court affirmed the decision of the lower court with a modification. The Court ruled that Section 2 of Rule 72 was inapplicable to both Tan Kue and the unauthorized occupants, Ang Ban and Ang Chung. The Court also held that Tan Kue's failure to pay rent was not due to force majeure and that he remained liable for the unpaid rentals from January 1945 until the property was vacated by Ang Ban and Ang Chung. The lease contract was declared terminated, and Tan Kue was ordered to vacate the premises. Rents due up to March 10, 1945, were subject to moratorium.
Ratio Decidendi
On Issue 1: The Court ruled that Section 2 of Rule 72 of the Rules of Court was not applicable to the defendants. Tan Kue could not invoke it because he was not sued for ejectment in accordance with Rule 72; the amended complaint only sought payment of unpaid rents, liquidated damages, attorney's fees, and costs. Ang Ban and Ang Chung could not invoke it either, as they were not tenants of the plaintiffs but mere intruders without any contractual relationship. Therefore, the notice requirement under that specific rule was irrelevant to their situation. On Issue 2: The Court found that whether Tan Kue's failure to pay rents was due to force majeure was immaterial for determining his obligation to pay the rents due. The obligation to pay was not denied. The Court reasoned that even if there was a justification for delay in payment prior to the liberation of Manila, there was no longer any justification after his return and resumption of business. His claim of being busy was insufficient to establish force majeure, especially since he had returned to Manila and was engaged in business. On Issue 3: The Court held that Tan Kue was equally responsible for the rents until Ang Ban and Ang Chung completely vacated the property. This was based on the evidence showing that Tan Kue had a role in his co-defendants' unjustifiable occupancy of the premises. His lease contract was terminated due to default in payment and breach of conditions, and his obligation to pay rents continued until the premises were returned to the lessors, irrespective of who was physically occupying them, as he had facilitated their entry and failed to fulfill his own obligations.
Main Doctrine
The Supreme Court affirmed the decision of the lower court, with a modification, holding that the lessee, Tan Kue, is liable for unpaid rentals from January 1945 until the premises are vacated by the unauthorized occupants, Ang Ban and Ang Chung. The Court found that Tan Kue's failure to pay rent was not due to force majeure, as he had returned to Manila and resumed business. Furthermore, the Court clarified that Section 2 of Rule 72 of the Rules of Court was inapplicable to the defendants. The lease contract between Epifiana Vda. de Guanzon and Tan Kue was deemed terminated, and Tan Kue was ordered to vacate the premises, despite his claim of evacuation.