G.R. No. 160014; February 18, 2005
Romeo Mendoza, petitioner, vs. The Court of Appeals and Manotok Services, Inc., respondents.

FACTS

Respondent Manotok Services, Inc. filed an ejectment complaint before the Metropolitan Trial Court (MeTC) of Manila against petitioner Romeo Mendoza and his predecessor, his father Benjamin. Manotok alleged it was the administrator of a parcel of land leased to Benjamin Mendoza, with the lease expiring on December 31, 1988. Despite the expiration, Benjamin and later Romeo continued occupying the premises without paying accrued rentals. After a demand letter dated July 16, 1996, addressed to “Mr. Benjamin Mendoza and all those persons claiming rights under him,” was ignored, Manotok sought ejectment and payment of unpaid rentals.
In his answer, petitioner Romeo Mendoza admitted Manotok was the lessor but denied knowledge of the specific lease contract and unpaid rentals. He asserted special defenses, including that the demand did not bind him as it was addressed to his deceased father, that rental increases were unconscionable, and that his long-term possession granted him protection under various social housing laws. He also challenged Manotok’s title. The MeTC ruled for Manotok, but the Regional Trial Court (RTC) reversed, dismissing the complaint for Manotok’s alleged failure to prove superior possessory right. The Court of Appeals reinstated the MeTC decision.

ISSUE

Whether the Court of Appeals erred in ruling that an action for unlawful detainer was proper and that petitioner Romeo Mendoza was bound by the lease contract and demand to vacate.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals. The action was correctly characterized as unlawful detainer, where the sole issue is physical possession independent of ownership claims. Petitioner lost his right to possess upon the lawful demand to vacate after the lease expired.
The legal logic rests on petitioner’s judicial admissions and the principle of estoppel. In his pleadings, petitioner explicitly admitted the lessor-lessee relationship, referring to himself as a “bona fide tenant-occupant” and acknowledging his father’s expired lease which he continued to occupy. Having voluntarily admitted his status as a tenant deriving rights from his father’s contract, he is estopped from denying the lease’s efficacy or his obligation thereunder. His attempt to question the contract’s validity, based on his father’s alleged prior death, is unavailing as a representative signed the 1988 lease without informing Manotok of the death, and petitioner himself benefited from the arrangement.
Furthermore, the demand to vacate was validly served. It was addressed not only to Benjamin Mendoza but also to “all those persons claiming rights under him,” which squarely covers petitioner, who derived his possession from his father. Therefore, the jurisdictional requirement for unlawful detainer was satisfied. The Court of Appeals correctly limited the resolution to the issue of possession, where Manotok, as the admitted lessor, held the better right following the lease termination and a valid demand.