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DIGNA CONSUMIDO v. REYNALDO G. ROS

FACTS:

The dispute in this case involves the possession of leased premises between petitioner Digna Consumido and respondent spouses Ramon, Jr. and Fatima Saura. The respondents claimed that they had entered into two lease contracts with the petitioner for two units on A.H. Lacson Street, Sampaloc, Manila. However, the petitioner defaulted on rental payments for the respective units in 1996 and 1997. As a result, the respondents filed an ejectment complaint seeking her eviction from the premises and payment of the accrued rentals.

In her defense, the petitioner argued that she had entered into the lease contracts with the late Ramon Saura, Sr. and had been paying rentals to the respondents who took over the management of the leased premises after his death. The petitioner also discovered that the leased premises had already been titled to Sandalwood Real Estate Development Corporation (SREDC). She actively negotiated with SREDC to continue her occupancy of the premises and disregarded the demands of the respondents.

Initially, the Metropolitan Trial Court (MeTC) dismissed the ejectment suit, citing ongoing litigation over the ownership of the leased premises. However, the Regional Trial Court (RTC) reversed the MeTC's decision and held that the respondents were entitled to the physical possession of the premises. The RTC ordered the petitioner to vacate the premises and pay the rental in arrears. The Court of Appeals upheld the RTC's decision. Dissatisfied with the findings of the lower courts, the petitioner filed a Rule 45 petition before the Supreme Court.

ISSUES:

  1. Whether respondent spouses are the real parties-in-interest to file the ejectment suit.

  2. Whether respondent spouses have the right to eject petitioner.

RULING:

  1. The Court of Appeals committed no reversible error in ruling that respondent spouses are the real parties-in-interest to file the ejectment suit. The appellate court found that petitioner herself admitted to remitting rentals to respondent spouses before she allegedly discovered that they were not the registered owners of the leased premises. Petitioner is precluded from controverting the title of her landlord and asserting any rights adverse to that title.

  2. The Court of Appeals also did not commit any error in ruling that respondent spouses have the right to eject petitioner. It was established that petitioner breached the lease agreement by defaulting on rental payments, and respondents, as the real parties-in-interest, are entitled to possession of the leased premises.

PRINCIPLES:

  • A lease agreement creates a legal relationship between the lessor and the lessee. The lessee is obligated to pay rentals, while the lessor is entitled to possession of the leased premises.

  • The registered owner of the leased premises has the right to eject a lessee who breaches the lease agreement and fails to pay the agreed rentals. The lessee cannot assert any rights adverse to the title of the landlord or set up any inconsistent right to change the existing relation between them.