G.R. No. 1511 : July 26, 1905
PARTIES:
Plaintiff-Appellant: Miguel Pascual
Defendant-Appellee: Macario Angeles
FACTS:
Miguel Pascual filed an action for ejectment against Macario Angeles to recover possession of a 15-yard square parcel of land in Uaua, San Jose de Navotas, and to collect unpaid rent. Pascual claimed ownership by inheritance from his sister, Ciriaca Pascual, the original lessor. He presented a written lease contract dated January 2, 1886, executed by Ciriaca Pascual (through Miguel Pascual) and Angeles, stipulating an annual rent of 10 pesos. Pascual alleged that Angeles paid rent from 1894 to 1898 but refused to pay for the years 1899, 1900, and 1901, and also refused to vacate the property.
Angeles entered a general denial and specifically denied under oath the genuineness of the lease. He asserted a special defense of ownership, claiming he had been in adverse, peaceful, and public possession of the land for over thirty years, during which he built houses and planted trees.
The trial court ruled in favor of Angeles. Pascual appealed, arguing that the court erred in its findings of fact and law.
ISSUE:
Whether the plaintiff-appellant, Miguel Pascual, is entitled to eject the defendant-appellee, Macario Angeles, for failure to pay the stipulated rent under their lease contract.
RULING:
YES. The Supreme Court reversed the trial court’s decision.
1. Existence and Validity of the Lease: The Court found the lease contract to be genuine and duly executed. Angeles himself admitted the genuineness of his signature thereon. The contract established the landlord-tenant relationship between the parties.
3. Rights of the Successor-in-Interest: The Court ruled that Miguel Pascual, as the testamentary heir of Ciriaca Pascual, succeeded to all her rights and obligations under the lease, including the right to collect rent and to eject the tenant for non-payment. Angeles had recognized this by paying rent to Pascual from 1894 to 1898.
4. Failure to Pay Rent as Ground for Ejectment: Non-payment of rent is a sufficient cause for the ejectment of a tenant under the lease and applicable jurisprudence. Angeles’s refusal to pay rent for 1899-1901 justified the action for unlawful detainer.
5. Identity of the Property and Defense of Ownership: The Court found that the identity of the land was established by the lease and the pleadings, as both parties referred to the same parcel. Angeles’s defense of ownership was unsustainable and contradicted by his prior recognition of Pascual’s title through rent payments.
DISPOSITIVE PORTION:
The judgment of the lower court was reversed. Macario Angeles was ordered to:
1. Vacate the land and return possession to Miguel Pascual within thirty days, subject to ejection upon failure to comply;
2. Pay Pascual all rent due; and
3. Pay the costs of suit.
The case was remanded to the trial court for execution.