GR 128636; (February, 2001) (Digest)
G.R. No. 128636. February 1, 2001
SPOUSES ZACARIAS BATINGAL and ELIZA BATINGAL, petitioners, vs. COURT OF APPEALS, JULIA TOLEDO, PETRONA TOLEDO and PAULINO TOLEDO, respondents.
FACTS
In Civil Case No. TG-925, petitioners, the Batingal spouses, were lessees of land owned by the Toledo siblings under a contract expiring on 31 December 1985. Despite demands, they refused to vacate after the lease ended, arguing they needed to harvest crops. They only returned possession in March 1987 during the pendency of the Toledos’ suit for recovery and damages. The Toledos, impoverished by the litigation, were forced to sell the land. In Civil Case No. TG-926, respondent Petrona Toledo mortgaged her separate land to Eliza Batingal to secure a P2,000 loan. After revoking a Special Power of Attorney given to Zacarias Batingal, Petrona offered to repay the loan to redeem the land, but the Batingals refused, presenting a purported “Kasunduan” (agreement) claiming they had bought the land. Petrona denied signing it, and an NBI expert confirmed the signature was forged.
ISSUE
The primary issues were: (1) whether petitioners were liable for damages for unlawfully withholding the leased property after the contract expired; and (2) whether the forged “Kasunduan” constituted a valid sale, obligating petitioners to return the mortgaged property to Petrona Toledo.
RULING
The Supreme Court affirmed the Court of Appeals with modifications. On the first issue, the Court upheld the award of damages. Petitioners’ refusal to vacate the leased land after the fixed-term contract expired constituted unlawful detention in bad faith. Their eventual return of possession during litigation was an implied admission of their lack of right. Thus, they were liable for actual damages measured by the lost rental income from 1986 to 1987, plus moral damages and attorney’s fees for causing the Toledos’ financial distress. On the second issue, the Court ruled the “Kasunduan” was void, being a forged document. It did not transfer ownership. Petitioners’ refusal to accept loan repayment and release the mortgage was unjustified. Consequently, the Court modified the appellate decision to explicitly order the Batingals to reconvey the mortgaged land to Petrona Toledo, in addition to paying her actual, moral, and exemplary damages, and attorney’s fees for their fraudulent retention of her property.