GR L 455; (October, 1901) (Digest)
G.R. No. L-455 : October 26, 1901
RAFAEL ENRIQUEZ, plaintiff-appellee, vs. A.S. WATSON & CO., defendants-appellants.
FACTS:
The defendants, A.S. Watson & Co., leased a building known as the English Dispensary from the Enriquez estate from January 1900 to May 1901. The stipulated rent for the entire period was paid. However, the rent for the period from January to May 1900 was paid twicefirst to the estate’s administrator and later deposited in court due to litigation between the heirs, brothers Francisco and Rafael Enriquez, over the administration of the estate. Rafael Enriquez sought to evict the defendants, alleging non-payment of rent for that period. A default judgment of eviction was rendered against the defendants on June 20, 1900. After September 1900, Francisco Enriquez took charge of the estate’s administration, recognized the defendants as tenants, and continued receiving rent. On January 25, 1901, Francisco entered into a new twelve-year lease with the defendants. When Rafael resumed administration in February 1901, he demanded rent from the defendants, who paid for April but refused to pay for March 1901, claiming they had already paid Francisco. Rafael then initiated proceedings to revive the 1900 default judgment for eviction.
ISSUE:
Whether the default judgment of eviction rendered on June 20, 1900, retained its executory force in light of subsequent acts by the estate’s administrators recognizing the defendants as tenants and accepting rent.
RULING:
No. The Supreme Court reversed the lower court’s judgment. The Court held that subsequent juridical acts between the defendants and the Enriquez estate, represented successively by administrators Francisco and Rafael Enriquez, effectively recognized the defendants as continuing tenants. These acts included Francisco’s acceptance of rent and execution of a new lease, and Rafael’s subsequent demand for and acceptance of rent for a later period. These acts rendered the 1900 default judgment ineffective and deprived it of executory force. The proper remedy for Rafael, if there was non-payment of rent for March 1901, was to file a new complaint based on that fact, not to revive the old judgment. Costs were taxed against the appellee.