GR 92540; (December, 1992) (Digest)
G.R. No. 92540 December 11, 1992
ANIANO TORRES and JOSEFINA TORRES, petitioners, vs. THE HON. COURT OF APPEALS, HON. REGIONAL TRIAL COURT OF NEGROS ORIENTAL, BRANCH 34, and ADELA B. FLORES, respondents.
FACTS
Petitioners Aniano and Josefina Torres were lessees of ten parcels of land owned by private respondent Adela B. Flores under contracts for a term of four agricultural years commencing from 1985. Before the contracts expired, the parties orally agreed to renew them under the original terms, subject to the condition that the lessees would deliver P50,000.00 in cash to Flores not later than February 15, 1989, which she needed for a projected trip abroad. The petitioners failed to deliver the full amount by the deadline, raising only P11,415.89. Consequently, Flores informed them on February 17, 1989, that she would take over the property upon the contracts’ expiration and later demanded they vacate. When the petitioners refused, Flores filed an action for illegal detainer. The Municipal Circuit Court ruled in favor of Flores, a decision affirmed by the Regional Trial Court and the Court of Appeals. The petitioners now seek review by the Supreme Court.
ISSUE
Whether the original contracts of lease were validly renewed.
RULING
No, the contracts were not validly renewed. The Supreme Court affirmed the lower courts’ findings. The agreement to renew was subject to a suspensive condition—the payment of P50,000.00 in cash by February 15, 1989. The petitioners’ failure to fully comply with this condition meant the obligation of Flores to renew the lease did not arise. The Court rejected the petitioners’ arguments. First, the acceptance of checks totaling P11,415.89 did not constitute compliance, as the amount was far short of the stipulated sum. Second, the doctrine of tacita reconduccion (implied renewal) did not apply because Flores had expressly given notice of her intention not to renew the lease and demanded the petitioners vacate, negating any acquiescence to their continued possession. Third, the issue of novation was raised too late, only at the Court of Appeals. Finally, the petitioners were not denied due process; the presumption is that the respondent court considered their supplemental motion for reconsideration but found it unmeritorious. The petition was denied.