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ROMEO JULAG-AY v. ESTATE OF FELIMON BUENAVENTURA

FACTS:

This case involves a petition for review on certiorari filed by Romeo Julag-ay against the Estate of Felimon Buenaventura, Sr., represented by its sole heir Teresita Rosalinda B. Mariano. The subject property of the case is Apartment 3, Block 1, Lot 111, Pleasant Village Subdivision, Muntinlupa City. Julag-ay had been leasing the property since 1995 and was paying monthly rent of P2,300.00, plus P200.00 for water supply.

Felimon Buenaventura, Sr. died intestate on October 15, 1996, and his son Felimon Buenaventura, Jr. took over the administration of the property. Julag-ay failed to pay his rentals for the whole year of 1998, amounting to P35,000.00. Felimon Buenaventura, Jr. later died on December 17, 1998, and Teresita assumed the administration of the property.

Julag-ay made some partial payments in early 1999 but failed to pay the remaining arrears. Teresita demanded that Julag-ay vacate the leased premises, but he refused. As a result, Teresita filed a complaint for ejectment against Julag-ay in June 1999.

The Metropolitan Trial Court initially dismissed the complaint, ruling that Teresita was not a real party-in-interest. However, the Regional Trial Court reversed the decision and ruled in favor of Teresita, noting that she had a better right to the possession of the property as the presumptive heir and administratrix of the estate.

Julag-ay filed a petition for review with the Court of Appeals, which was subsequently denied. Julag-ay then filed a petition for review on certiorari with the Supreme Court, challenging the decision of the Court of Appeals.

ISSUES:

  1. Whether TERESITA has legal personality to file the ejectment case as the representative of the Estate of Felimon Buenaventura Sr.

  2. Whether the issue of ownership is relevant in the ejectment case.

  3. Whether JULAG-AY is estopped from denying the title of his lessor.

  4. Whether the Regional Trial Court's minute Order (dated September 25, 2000) is unconstitutional.

RULING:

  1. Yes, TERESITA has legal personality to file the ejectment case as the representative of the Estate of Felimon Buenaventura Sr. The Regional Trial Court correctly found that TERESITA, as the sole presumptive heir and administratrix of the estate, has a better right to possession of the property over JULAG-AY.

  2. No, the issue of ownership is irrelevant in the ejectment case. What should be determined is who has a better right to possession of the property. Even if ownership of the property is in dispute, TERESITA, as the administratrix and presumptive heir, has the better right to possession.

  3. Yes, JULAG-AY is estopped from denying the title of his lessor. By consistently paying rent to the deceased Felimon Buenaventura Sr., and later to TERESITA after her appointment as administratrix, JULAG-AY recognized TERESITA's right and authority to receive the rents over the property.

  4. No, the Regional Trial Court's minute Order (dated September 25, 2000) is not unconstitutional. The Court of Appeals correctly affirmed this ruling, as there was no showing of any constitutional violation in the issuance of the order.

PRINCIPLES:

  • In an ejectment case, the issue of ownership is irrelevant. What should be determined is who has a better right to possession of the property.

  • A real party-in-interest has legal personality to file an ejectment case.

  • A lessee is estopped from denying the title of his lessor if he has consistently recognized the lessor's right and authority to receive rents over the property.

  • A minute Order issued by the court is not necessarily unconstitutional unless there is a showing of a constitutional violation.