GR 128568; (April, 2003) (Digest)
G.R. No. 128568 ; April 9, 2003
SPOUSES REYNALDO ALCARAZ and ESMERALDA ALCARAZ, petitioners, vs. PEDRO M. TANGGA-AN, et al., and HON. JUDGE P. BURGOS and THE COURT OF APPEALS, respondents.
FACTS
Respondents, heirs of the late Virginia Tangga-an, filed an unlawful detainer complaint against petitioner spouses. The petitioners had leased a residential building from Virginia under a five-year contract requiring a monthly rental of P4,000. The lot on which the house stood was owned by the National Housing Authority. Petitioners ceased paying rent to the respondents starting November 1993, accumulating arrears of P48,000. Respondents demanded payment and possession, seeking to repossess the property for their own use.
Petitioners defended their non-payment by asserting that the ownership of the lot was transferred to Virgilio Tangga-an, a son of Virginia, in July 1993. They argued this transfer of the lot’s title effectively cancelled their lease contract with the respondents. Consequently, they began paying rent to Virgilio, believing the respondents no longer had the legal right to collect. They maintained that the respondents’ claim over the house was undermined by Virgilio’s ownership of the land.
ISSUE
Whether the petitioners were justified in unilaterally suspending rental payments to the respondents and paying Virgilio instead, thereby warranting dismissal of the ejectment case.
RULING
The Supreme Court ruled against the petitioners and affirmed the ejectment order. The legal logic is anchored on the distinct concepts of ownership and possession in lease contracts, and the principle of relativity of contracts. The lease contract was between the petitioners and Virginia (succeeded by her heirs, the respondents). This contract concerned the use of the building, not the land. Ownership of the land is separate from ownership of the improvements upon it. The subsequent transfer of the lot’s title to Virgilio did not automatically transfer ownership of the house or nullify the existing lease agreement. The respondents sufficiently established their claim as owners and lessors of the building through evidence like tax declarations.
The petitioners’ defense of payment in good faith to Virgilio under Article 1242 of the Civil Code fails. They admitted they paid Virgilio because they believed he was the sole owner, not because he was collecting as a co-heir. Payment to a third party claiming adverse ownership does not constitute payment in good faith to a person in possession of the credit when the debtor is aware of a conflicting claim. The proper recourse for the petitioners, faced with conflicting demands for rent, was to file an interpleader action and deposit the rentals in court, not to unilaterally rescind the contract. Having violated the essential obligation to pay rent to the respondents as lessors, the petitioners were legally liable for ejectment. The pending litigation regarding the lot’s ownership was irrelevant to the summary issue of physical possession in the ejectment case.