Shoemart v. The Honorable Court of Appeals

Summary

This case involves a lease dispute between Shoemart, Inc. and Anson Emporium Corporation over premises in Makati Arcade. After a two-year lease expired in 1973, Anson remained as a holdover tenant on a month-to-month basis. When Shoemart terminated this arrangement in 1977 and demanded vacation, Anson refused, leading to an ejectment suit. The key legal issue was whether Shoemart could recover damages based on four rental increases implemented during the unlawful detainer period, despite these increases not being specifically pleaded in the supplemental complaint. The Supreme Court ruled that the original complaint's prayer for 'all other rentals due' was sufficient, and since evidence of the increases was presented without objection, they should be treated as if pleaded under Rule 10, Section 5. However, the Court excluded interest (no written stipulation after lease termination per Article 1956) and electricity costs (must be claimed separately). The decision establishes important precedents on supplemental pleadings, holdover tenancy, and damages in ejectment cases.