Heirs of Antonio Feraren v. Court of Appeals (Former 12Th Division)

Summary

The Supreme Court affirmed the Court of Appeals' decision in an unlawful detainer case involving the Heirs of Antonio Feraren and property owner Cecilia Tadiar. The core dispute centered on whether lessees who built improvements on leased property could compel reimbursement before vacating. The Court held that petitioners made a judicial admission in their Answer that their house was constructed during the lease period, not during ownership under a pacto de retro arrangement. Applying Article 1678 of the Civil Code, the Court ruled that since the lessor (Tadiar) preferred demolition over appropriating the improvements, she cannot be compelled to reimburse the lessees. The case establishes that lessees cannot contradict judicial admissions absent proof of palpable mistake and clarifies the lessor's options regarding improvements under Article 1678. The decision also reinforced strict adherence to procedural deadlines in summary proceedings, noting that petitioners' late-filed position paper should have been excluded.