Spouses Alejandro Manzanilla v · G.R. 177484

Petitioner: Spouses Alejandro Manzanilla
Respondent: Waterfields Industries Corporation
Citation: G.R. No. 177484
Court: Supreme Court
Division: Second Division
Ponente: Del Castillo, J.
Decided: July 18, 2014

Summary

This case involves an unlawful detainer action filed by lessors spouses Manzanilla against lessee Waterfields Industries Corporation for non-payment of rent from December 1997 to May 1998. The key issue was whether a rental deposit could be applied to rental payments after the lease contract was amended through the lessee's letter restricting deposit use to utilities and incidental expenses only. The Metropolitan Trial Court and Regional Trial Court ruled in favor of the lessors, finding the amendment valid and ordering ejectment. The Court of Appeals reversed by applying compensation principles, but the Supreme Court ultimately reinstated the trial courts' decisions, emphasizing that the cause of action for unlawful detainer arises from failure to pay rent, and that the lessee was bound by its judicial admission regarding the contract amendment. The decision clarifies the requisites for unlawful detainer actions and the binding nature of judicial admissions in contract disputes.

Statutes applied

Civil Code, Art. 1278

Related cases

Other Philippine cases on the same provisions and issues.

Rosemarie Q. Rey v. Cesar G. Anson G.R. No. 211206
Jose Vaca v. Manuel Kosca G.R. No. 8394
Bonifacia Manalo v. Gregorio de Mesa G.R. No. 9449
Thunga Chui v. Que Bentec G.R. No. 929
H.S. Pow Construction v. Shaughnessy Development Corporation G.R. No. 229262
Jennefer Figuera v. Maria Remedios Ang G.R. No. 204264
Special Steel Products v. Lutgardo Villareal G.R. No. 143304
Ckh Industrial v. The Court of Appeals G.R. No. 111890

By the Intellegal Editorial Board · July 18, 2014

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