GR 200612; (April, 2017) (Digest)
G.R. No. 200612. April 05, 2017
RAFAEL C. UY (CABANGBANG STORE), PETITIONER, VS. ESTATE OF VIPA FERNANDEZ, RESPONDENT.
FACTS
Vipa Fernandez Lahaylahay, the registered owner of a parcel of land, leased the property to Rafael Uy. After Vipa’s death in 1994, her daughter Grace Joy acted as the estate’s de facto administrator, and Uy paid rent to her until June 1998. Uy then ceased payments, claiming confusion over the rightful recipient due to a claim by Vipa’s sister, Patria Fernandez-Cuenca. Uy made consignations totaling P16,000 with the court. In 2003, the Estate of Vipa, through Grace Joy, filed an unlawful detainer case against Uy in the MTCC for unpaid rentals.
The MTCC ruled for the estate, ordering Uy to vacate and pay arrears. The RTC reversed, dismissing the complaint. It held that Grace Joy was the real plaintiff and failed to undergo barangay conciliation. It also ruled the property was conjugal, and after Vipa’s death, her surviving husband Levi owned half. Since Levi sold his share to Uy in 2005, Uy became a co-owner with a right to possess. The CA reinstated the MTCC decision, ruling barangay conciliation was inapplicable to a juridical entity like an estate and that Uy’s purchase of Levi’s share did not negate his obligation under the lease.
ISSUE
Whether the Supreme Court affirms the Court of Appeals’ reinstatement of the MTCC decision in favor of the Estate of Vipa.
RULING
Yes, the Supreme Court affirmed the CA decision with modification on the interest rate. The Court clarified that prior barangay conciliation was unnecessary as the complaint was filed by the Estate of Vipa, a juridical entity exempt from such requirement under the Revised Rules on Summary Procedure. Grace Joy’s authority was subsequently confirmed by her judicial appointment as administrator.
On the core issue of possession, the Court held that Uy’s purchase of Levi’s undivided share in the conjugal property did not extinguish the lease contract or legitimize his detainer. A lease is a personal relation between lessor and lessee. Uy, as a lessee, cannot unilaterally convert his status to that of a co-owner to avoid his contractual obligations. His remedy was to pay the rent due to the estate as the lessor. His consignations were invalid for lack of a valid prior tender of payment to the rightful obligee. Consequently, his failure to pay rent constituted a violation of the lease terms, justifying ejectment. The Court modified the imposed interest to 12% per annum from June 12, 2003, until June 30, 2013, and 6% per annum thereafter until full payment.