Zosima Incorporated v. Lilia Salimbagat

Summary

Zosima Incorporated filed unlawful detainer against lessee Lilia Salimbagat for allegedly occupying office building without paying rent from April 2000-October 2003, claiming P628,703.00 in arrears. Salimbagat defended that the leased office building was demolished for LRT construction and she now occupies a different warehouse she purchased. Lower courts initially ruled for Zosima, but Court of Appeals reversed, finding insufficient evidence of unlawful possession. Supreme Court affirmed dismissal, emphasizing that in ejectment cases, plaintiff bears burden of proving defendant's actual possession by preponderance of evidence. Zosima failed to establish that Salimbagat possessed the office building during the alleged period, particularly given the 3-year delay in filing suit and Salimbagat's evidence of owning different property. The case demonstrates the strict evidentiary requirements in unlawful detainer actions and principles of tacita reconduccion under Civil Code Articles 1670 and 1687.