Leus v. Martin
REITERATIONFacts
The Antecedents: Plaintiffs, as owners of a house, sought to eject the defendant for failure to pay monthly rentals for August and September 1945. The agreed monthly rental was P12. Procedural History: The Municipal Court of Manila rendered a decision in favor of the plaintiffs. The defendant appealed to the Court of First Instance of Manila. Subsequently, the defendant was declared in default for failure to file an answer, and a decision was rendered ordering him to vacate the premises and pay rents in arrears and those that may become due until he vacates. The defendant appealed again. The Petition: Plaintiffs-appellees filed a petition praying that the moneys deposited by the defendant-appellant as monthly rentals with various courts be turned over to them and that the defendant be required to surrender the receipts for said deposits.
Issue(s)
Whether the plaintiffs-appellees are entitled to withdraw the monthly rentals deposited by the defendant-appellant with the courts during the pendency of the appeal. Whether the defendant-appellant should be required to surrender the receipts for the deposited moneys.
Ruling
The petition to withdraw the rents deposited is granted; but his petition to require the defendant to surrender the receipts for moneys deposited, being groundless and unnecessary, is denied.
Ratio Decidendi
On the entitlement to withdraw deposited rentals: The Court reiterated the settled principle that when a defendant agrees or fails to oppose a plaintiff's petition to withdraw moneys deposited as rentals during the pendency of an appeal, the petition must be granted. The Court emphasized that the Rules of Court, specifically sections 8 and 9 of Rule 72, are not rigid ends in themselves but are means to serve the interest of justice. In this case, the defendant's failure to oppose the plaintiffs-appellees' petition was taken as acquiescence. The Court noted that while the rules generally hold deposited moneys until final disposition of the appeal, it has, on more than one occasion, allowed the turning over of such moneys to plaintiffs when justice demands it and no issue is raised by the defendant regarding the plaintiff's right to collect. The purpose of the rule is to protect the defendant from suffering if the plaintiff's right to collect is in issue; where no such issue is raised, there is no harm to be protected against. On the requirement to surrender receipts: The Court denied the plaintiffs' petition to require the defendant to surrender the receipts for the deposited moneys, finding this request to be groundless and unnecessary. The primary concern was the disposition of the deposited funds, and the surrender of receipts was not essential to achieve the objective of allowing the plaintiffs to withdraw the funds they were deemed entitled to, especially since the defendant had not opposed the withdrawal.
Main Doctrine
The withdrawal of deposited rentals by the plaintiff during the pendency of an appeal may be granted if the defendant agrees or fails to oppose the plaintiff's petition, as the Rules of Court are means to serve the interest of justice and not ends in themselves.