GR 131726; (May, 2002) (Digest)
G.R. No. 131726 May 7, 2002
YOLANDA PALATTAO, petitioner, vs. THE COURT OF APPEALS, HON. ANTONIO J. FINEZA, as Presiding Judge of the Regional Trial Court of Caloocan City, Branch 131 and MARCELO CO, respondents.
FACTS
Petitioner Yolanda Palattao leased a property to private respondent Marcelo Co under a three-year contract (1991-1993) containing a first-option-to-purchase clause. During the final year, they negotiated a sale. Petitioner made a formal offer in November 1993, which respondent accepted. The offer required a 50% downpayment by November 24, 1993, failing which petitioner could sell to others. Petitioner also notified respondent of non-renewal of the lease expiring December 31, 1993. Respondent did not pay the downpayment. Instead, on November 29, 1993, he sent a letter proposing to renew the lease for another three years, which petitioner rejected. Respondent then filed a specific performance case to compel the sale and obtained a status quo agreement. Petitioner subsequently filed an ejectment case after the lease expired.
ISSUE
The core issues were: (1) whether a perfected contract of sale existed, barring ejectment; (2) whether the status quo agreement in the specific performance case estopped petitioner from filing ejectment; and (3) whether respondent had a right to remain in possession after the lease expired.
RULING
The Supreme Court granted the petition, reinstating the Metropolitan Trial Court’s ejectment decision with modification on rental. There was no perfected contract of sale. A contract of sale requires a meeting of minds on the object and price. While petitioner’s offer was accepted, the acceptance was not absolute; respondent’s subsequent proposal to renew the lease constituted a counter-offer, effectively rejecting the original offer and negating perfection. The status quo agreement in the specific performance case pertained only to maintaining possession during those proceedings and did not constitute an indefinite waiver of the right to file ejectment. Estoppel did not apply. With the lease contract expired and not renewed, and with no perfected sale, respondent became a deforciant possessor with no right to remain. His right of possession, derived solely from the lease, terminated on December 31, 1993. Thus, ejectment was proper. The reasonable compensation for use was reduced to P8,500.00 monthly, the highest rent stipulated in the original contract.