The Supreme Court has clarified the rules against splitting a cause of action, especially in property lease disputes. The Court ruled that a landowner can file a separate action for collection of unpaid rent even while an ejectment case is ongoing, provided the unpaid rent pertains to a period before the unlawful detainer commenced. This decision offers clarity to property owners on how to pursue legal remedies effectively without violating procedural rules. This case underscores the importance of understanding the distinct causes of action available to landowners and the remedies they can seek in different legal proceedings.

Lease Dispute Maze: Can Landowners Untangle Unpaid Rent from Ejectment Actions?

This case, Lajave Agricultural Management and Development Enterprises, Inc. v. Spouses Agustin Javellana and Florence Apilis-Javellana, revolves around a lease agreement for agricultural land. Lajave leased land from Agustin Javellana, initially under a written contract and later under a tolerated occupancy. A dispute arose over unpaid rentals, leading Agustin to file both unlawful detainer cases to evict Lajave and a separate collection case to recover the rental deficiencies. Lajave argued that Agustin was splitting his cause of action, violating the principles of litis pendentia and forum shopping. The central legal question is whether Agustin could pursue the collection case independently while the ejectment suits were pending.

The Supreme Court addressed the core issues of litis pendentia, splitting a cause of action, and forum shopping. Litis pendentia occurs when there is another pending action between the same parties for the same cause of action, making the second action unnecessary. The requisites for litis pendentia are: (a) identity of parties; (b) identity of rights asserted and relief prayed for; and (c) such identity that a judgment in the pending case would amount to res judicata in the other. Res judicata prevents parties from relitigating issues already decided by a competent court.

The Court found that the second and third requisites of litis pendentia were absent in this case. While the parties and properties were the same, the causes of action differed. In the unlawful detainer cases, the cause of action was Lajave’s failure to vacate the property and pay rentals after the demand to vacate. In contrast, the collection case was based on Lajave’s alleged violation of the lease agreement concerning the payment of rental fees for periods prior to the unlawful detainer.

The Supreme Court emphasized the limited scope of recoverable damages in ejectment cases. As stated in the case of Araos v. Court of Appeals:

[T]he damages which could be recovered are those which the plaintiff could have sustained as a mere possessor, or those caused by the loss of the use and occupation of the property, and not the damages which he may have suffered but which have no direct relation to his loss of material possession.

This means that in ejectment cases, only damages directly related to the loss of possession can be recovered, such as the fair rental value or reasonable compensation for the use of the property after the possession becomes unlawful. Other damages, like rental deficiencies that accrued before the unlawful detainer, must be claimed in a separate ordinary action.

The Court highlighted that the determination of rental deficiencies requires a full-blown trial. Factors such as the correct rental amount, the parties’ intentions regarding payment terms, and the verification of payment records must be considered. These issues cannot be resolved in the summary proceeding of an ejectment case. Therefore, the collection case was necessary to address the rental deficiencies that fell outside the scope of the unlawful detainer actions.

The Supreme Court also addressed the issue of splitting a cause of action. Splitting a cause of action is a form of forum shopping where multiple cases are filed based on the same cause of action but with different prayers. The Court clarified that the collection case did not constitute splitting a cause of action because the damages sought were different from those recoverable in the ejectment cases. The collection case aimed to recover rental deficiencies that had no direct relation to the loss of possession, while the ejectment cases sought to recover possession and damages resulting from the unlawful detainer.

The Court also cited Section 5, Rule 2 of the Rules of Court, which prohibits the joinder of special civil actions, like ejectment, with ordinary civil actions, such as collection of sum of money. The court stated:

Section 5. Joinder of causes of action. – A party may in one pleading assert, in the alternative or otherwise, as many causes of action as he may have against an opposing party, subject to the following conditions:

(b) The joinder shall not include special civil actions or actions governed by special rules;

This rule underscores the procedural distinction between ejectment cases and ordinary civil actions and supports the permissibility of filing separate suits in this scenario. Building on this principle, the Supreme Court determined that the collection case was properly filed as a separate action. This ruling provides a clearer understanding of the scope of damages recoverable in ejectment cases and the circumstances under which separate actions may be pursued.

In conclusion, the Supreme Court held that Agustin did not violate the rules on forum shopping, splitting a cause of action, or litis pendentia by filing the collection case during the pendency of the unlawful detainer cases. The Court reasoned that the causes of action were distinct, the damages sought were different, and the procedural rules allowed for separate actions in this context. This decision reaffirms the principle that landowners can pursue all available legal remedies to protect their rights, provided they do so in accordance with the established rules of procedure.

FAQs

What was the key issue in this case?	The key issue was whether a landowner could file a separate action for collection of unpaid rent while an ejectment case was ongoing without violating the rules against splitting a cause of action, litis pendentia, and forum shopping.
What is litis pendentia?	Litis pendentia refers to a situation where another action is pending between the same parties for the same cause of action, rendering the second action unnecessary. It requires identity of parties, rights asserted, and such identity that a judgment in one case would amount to res judicata in the other.
What damages can be recovered in an unlawful detainer case?	In an unlawful detainer case, the recoverable damages are generally limited to the fair rental value or reasonable compensation for the use and occupation of the property after the possession becomes unlawful. Other damages must be claimed in a separate ordinary action.
What is splitting a cause of action?	Splitting a cause of action is a form of forum shopping where multiple cases are filed based on the same cause of action but with different prayers, contrary to the principle that the entire cause must be determined in one action.
Why was the collection case allowed in addition to the ejectment cases?	The collection case was allowed because it sought to recover rental deficiencies that accrued before the unlawful detainer commenced, and these damages were not directly related to the loss of possession, thus not recoverable in the ejectment cases.
What does the Rules of Court say about joining special civil actions?	Section 5, Rule 2 of the Rules of Court prohibits the joinder of special civil actions, like ejectment, with ordinary civil actions, such as collection of sum of money, emphasizing the procedural distinction between these types of cases.
What must be proven in a collection case for rental deficiencies?	In a collection case for rental deficiencies, the correct rental amount, the parties’ intentions regarding payment terms, and the verification of payment records must be considered, requiring a full-blown trial.
When does possession become unlawful in an unlawful detainer case?	Possession becomes unlawful in an unlawful detainer case after the demand to vacate is made and the possessor fails to comply within the specified period.

This case offers valuable guidance for property owners navigating lease disputes. By understanding the distinct causes of action and the permissible scope of remedies, landowners can effectively protect their rights without running afoul of procedural rules. The Supreme Court’s decision reinforces the importance of strategic legal planning and the careful consideration of available legal options.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: LAJAVE AGRICULTURAL MANAGEMENT AND DEVELOPMENT ENTERPRISES, INC. VS. SPOUSES AGUSTIN JAVELLANA AND FLORENCE APILIS-JAVELLANA, G.R. No. 223785, November 07, 2018