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VIEGELY SAMELO v. MANOTOK SERVICES

FACTS:

Viegely Samelo (petitioner) entered into a lease contract with Manotok Services, Inc. (respondent) for a portion of Lot 9-A, Block 2913 in Manila. After the expiration of the lease contract, the petitioner continued occupying the premises without paying rent. The respondent demanded that the petitioner vacate the premises and pay compensation, but the petitioner refused. The respondent filed a complaint for unlawful detainer before the Metropolitan Trial Court (MeTC), which ruled in favor of the respondent. The MeTC ordered the petitioner to vacate the premises and pay compensation. The petitioner appealed to the Regional Trial Court (RTC), which reversed the MeTC's decision and dismissed the complaint. The respondent filed a petition for review with the Court of Appeals (CA), which reinstated the MeTC judgment. The CA held that the petitioner is now estopped from questioning the respondent's right over the premises and that only the issue of possession is relevant in an ejectment suit. The petitioner filed a petition for review on certiorari before the Supreme Court, arguing that the CA erred in its ruling.

ISSUES:

  1. Whether the petitioner is estopped from questioning the respondent's right over the subject premises.

  2. Whether the petitioner's filing of a case for fraudulent misrepresentation, annulment of lease contract, and quieting of title constitutes repudiation of the lease contract.

RULING:

  1. Yes, the petitioner is estopped from questioning the respondent's right over the subject premises. In an action involving possession, a tenant cannot controvert the title of his landlord or assert any rights adverse to that title, without first delivering the premises to the landlord.

  2. No, the petitioner's filing of a case for fraudulent misrepresentation, annulment of lease contract, and quieting of title does not constitute repudiation of the lease contract. There were no unequivocal acts of repudiation.

PRINCIPLES:

  • In an ejectment suit, the only issue is physical or material possession, and the issue of ownership is not required to determine possession.

  • A tenant is estopped from questioning the right of his landlord over the subject property, without delivering the premises acquired by virtue of their agreement.