G.R. No. 75909 February 5, 1990
RAMON FRANCISCO and CRISTINA MANALO, petitioners, vs. INTERMEDIATE APPELLATE COURT, HON. BERNARDO P. PARDO, Presiding Judge, Regional Trial Court, National Capital Judicial Region, Branch XLIII, and SPS. BENJAMIN BANGAYAN and EMILIANA BANGAYAN, respondents.

FACTS

Petitioners Ramon Francisco and Cristina Manalo were lessees of a property in Manila owned by Antonio Chua since 1961. In 1978, private respondents Benjamin and Emiliana Bangayan purchased the property. An arrangement was made where the petitioners would continue paying rent to Chua until the end of 1978, after which rentals would accrue to the Bangayans. However, starting January 1979, Chua assumed responsibility for paying the rent on behalf of the petitioners directly to the Bangayans. Chua subsequently defaulted on these payments from September 1979. The Bangayans made written demands for payment, including letters sent to the petitioners in July 1982 and January 1983, which were returned unclaimed. The petitioners stopped paying rent after receiving a copy of a demand letter the Bangayans sent to Chua in February 1982.
In March 1983, the Bangayans filed an ejectment complaint in the Metropolitan Trial Court (MTC) on grounds of non-payment of rent and alleged subleasing. The MTC ruled in favor of the Bangayans, ordering the petitioners to vacate and pay accrued rentals. This decision was affirmed by the Regional Trial Court (RTC) and subsequently by the Intermediate Appellate Court (IAC).

ISSUE

The core issue is whether the petitioners were validly ejected from the leased premises for non-payment of rentals.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ decisions. The legal logic is anchored on the nature of lease relations and the obligations of a lessee. First, the petitioners’ argument that no contract of lease existed with the Bangayans is untenable. Under Article 1676 of the Civil Code, the purchaser of a leased property generally subrogates into the rights and obligations of the former lessor, and the lease continues unless terminated under the law. The Bangayans chose to continue the lease, thereby establishing a landlord-tenant relationship with the petitioners.
Second, the petitioners’ failure to pay rent constituted a valid ground for ejectment. The Court emphasized that a lessee cannot refuse to pay rent simply because negotiations for a new rental rate fail. The lease, being on a month-to-month basis, allowed the lessor to demand a new rental. The petitioners, by continuing to occupy the property and derive benefit from it, were obligated to pay the reasonable rental fixed by the owner. Their complete cessation of payment, justified only by a dispute over the rate, unjustly enriched them at the expense of the Bangayans, contravening the legal maxim nemo cum alterius detrimento locupletari potest.
Third, the demand letters sent to the petitioners, though returned unclaimed, were deemed sufficient. The Court cited precedent that a party cannot profit from refusing to receive a valid notice. Finally, the Court found no abuse of discretion in the lower courts’ refusal to fix a longer lease period under Article 1687, as the petitioners’ default in payment justified their ejectment. Thus, the petition was denied for lack of merit.