Petitioner
Abaya Investments Corporation
Respondent
Merit Philippines
Citation
G.R. No. 176324
Court
Supreme Court
Division
Third Division
Ponente
Ynares-Santiago, J.
Decided
April 16, 2008

Summary

This unlawful detainer case involved Abaya Investments Corporation's ejectment of Merit Philippines from Carmen Building due to rental arrears and unauthorized subleasing. The Metropolitan Trial Court and Regional Trial Court ruled for the lessor, but the Court of Appeals reversed, holding that contract rescission was required before ejectment, making the case beyond MTC jurisdiction. The Supreme Court reversed the CA, clarifying that lease contract violations under Article 1673 of the Civil Code allow direct ejectment without prior rescission proceedings, distinguishing this from contracts to sell. The Court emphasized that jurisdiction depends on complaint allegations, and unlawful detainer was properly pleaded. The decision reinforced lessors' rights to judicial ejectment for non-payment and lease violations, while also applying substantial justice principles regarding procedural requirements for corporate certifications.

Statutes applied

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By the Intellegal Editorial Board · April 16, 2008

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