G.R. No. 271967 , November 04, 2024
ROLLY B. LAQUI, SR., PETITIONER, VS. ALEX E. SAGUN, NELIA S. ESPIRITU, KATHERINE MARIE T. SAGUN, HEREIN REPRESENTED BY MARY JANE S. CUEVAS, RESPONDENTS

FACTS

The respondents, heirs of Remedios E. Sagun, are co-owners of a property in Baguio City, which they inherited. Petitioner Rolly B. Laqui, Sr. had been leasing the property from Remedios since 2002 under agreements that expired and were impliedly renewed on a month-to-month basis. In 2019, respondents demanded that Laqui vacate. A barangay amicable settlement was reached on September 24, 2019, wherein Laqui agreed to vacate within six months (by March 2020) and pay monthly rent of PHP 5,300.00. Laqui failed to vacate. Respondents filed a complaint in the MTCC to enforce the amicable settlement. In his Answer, Laqui generally denied the allegations for lack of knowledge and raised an affirmative defense, claiming he could not be ejected because the property was part of the “Estate of Acopiado” and had been assigned to him by its administrator via a Deed of Assignment dated October 30, 2019. Respondents moved for judgment on the pleadings, arguing Laqui’s Answer failed to properly deny the material allegations. The MTCC granted the motion, ruling Laqui’s general denial constituted an admission and that his affirmative defense was barred by the finality of the amicable settlement and the principle of estoppel against a lessee challenging the lessor’s title. The MTCC ordered Laqui to vacate and pay rent. The RTC and the CA affirmed the MTCC’s judgment.

ISSUE

1. Whether the Court of Appeals erred in affirming the lower courts’ ruling that a judgment on the pleadings was properly rendered even without a pretrial conference.
2. Whether the Court of Appeals erred in affirming the denial of petitioner’s affirmative defense.

RULING

The Supreme Court denied the petition, ruling it was without merit.
1. On the propriety of judgment on the pleadings: The Supreme Court held that while the MTCC’s act of rendering a judgment on the pleadings was technically improper because Laqui’s Answer, by raising an affirmative defense, did tender an issue, the judgment shall be treated as a summary judgment under Rule 35. A summary judgment is proper when, upon the pleadings and supporting documents, there is no genuine issue as to any material fact. Here, Laqui’s Answer failed to specifically deny the material allegations regarding the amicable settlement and his non-compliance, which were deemed admitted. His affirmative defense, based on the Deed of Assignment, did not constitute a genuine issue because it was insufficient to overcome respondents’ title and the binding amicable settlement. The Court also clarified that a pretrial conference is not a prerequisite for a judgment on the pleadings or a summary judgment.
2. On the affirmative defense: The Supreme Court affirmed that Laqui is estopped from challenging respondents’ title. As a lessee, he is prohibited by Article 1436 of the Civil Code and Section 2(b), Rule 131 of the Rules of Court from disputing his lessor’s title. His claim of ownership via a Deed of Assignment from an estate administrator is invalid. An administrator’s powers are limited to possession, management, and preservation of the estate for payment of debts and expenses, and any sale or encumbrance requires prior court approval under Rule 89 of the Rules of Court. No such approval was shown. Furthermore, the amicable settlement, which had the force of res judicata, already bound Laqui to vacate. Thus, his affirmative defense was correctly rejected.