In unlawful detainer cases under summary procedure, the Supreme Court has clarified that when a defendant fails to file an answer, the court must render judgment based solely on the facts alleged in the complaint, not on the weight of evidence presented. This means that if a complaint sufficiently states a cause of action for unlawful detainer, a judgment can be rendered in favor of the plaintiff without requiring additional proof. This ruling emphasizes the importance of a well-pleaded complaint and streamlines the process for resolving ejectment cases when defendants fail to respond.
When Silence Speaks Volumes: Default and the Unlawful Detainer Action
This case revolves around a dispute between Fairland Knitcraft Corporation (Fairland) and Arturo Loo Po (Po) concerning a condominium unit in Pasig City. Fairland alleged that Po had been leasing the unit under a verbal agreement but failed to pay rent, prompting Fairland to demand payment and eviction. When Po failed to respond to the unlawful detainer complaint filed by Fairland, the Metropolitan Trial Court (MeTC) dismissed the case, citing Fairland’s failure to prove its claim by preponderance of evidence. The Regional Trial Court (RTC) and Court of Appeals (CA) affirmed this decision. The central legal question is whether the lower courts erred in requiring Fairland to prove its case by preponderance of evidence, despite Po’s failure to file an answer, as required by the Rules on Summary Procedure.
Fairland argued that in ejectment cases where no answer is filed, judgment should be based on the facts alleged in the complaint, not on the standard of preponderance of evidence. According to Fairland, Po’s failure to file an answer was tantamount to an admission of the allegations in the complaint. In response, Po contended that the court still had the discretion to evaluate the pleadings and that Fairland had failed to substantiate its claims with competent evidence, such as proof of ownership or a lease contract. The Supreme Court disagreed with the lower courts and sided with Fairland, highlighting the specific rules governing unlawful detainer cases under summary procedure.
The Supreme Court emphasized that a complaint for unlawful detainer sufficiently states a cause of action if it recites the following elements: (1) initial possession by contract or tolerance of the plaintiff; (2) subsequent illegality of possession upon notice of termination; (3) continued possession by the defendant depriving the plaintiff of enjoyment; and (4) filing of the complaint within one year from the last demand to vacate. The Court found that Fairland’s complaint met these requirements, as it alleged ownership, a verbal lease agreement, non-payment of rent, a demand to pay and vacate, and the filing of the complaint within the prescribed period. The Court quoted Section 1 of Rule 70 of the Rules of Court, which outlines the requirements for filing an unlawful detainer complaint:
Section 1. – Who may institute proceedings, and when. – Subject to the provision of the next succeeding section, a person deprived of the possession of any land or building by force, intimidation, threat, strategy, or stealth, or a lessor, vendor, vendee, or other person against whom the possession of any land or building is unlawfully withheld after the expiration or termination of the right to hold possession, by virtue of any contract, express or implied, or the legal representatives or assigns of any such lessor, vendor, vendee, or other person, may, at any time within one (1) year after such unlawful deprivation or withholding of possession, bring an action in the proper Municipal Trial Court against the person or persons unlawfully withholding or depriving of possession, or any person or persons claiming under them, for the restitution of such possession, together with damages and costs.
The court clarified that, given Po’s failure to file an answer, the MeTC should have rendered judgment based on the allegations in Fairland’s complaint, not on a failure to prove ownership by preponderance of evidence. Sections 5 and 6 of the Rules on Summary Procedure were crucial to this determination. Section 6 specifically states:
Sec. 6. Effect of failure to answer. – Should the defendant fail to answer the complaint within the period above provided, the court, motu proprio or on motion of the plaintiff, shall render judgment as may be warranted by the facts alleged in the complaint and limited to what is prayed for therein. The court may in its discretion reduce the amount of damages and attorney’s fees claimed for being excessive or otherwise unconscionable, without prejudice to the applicability of Section 4, Rule 18 of the Rules of Court, if there are two or more defendants.
The Supreme Court emphasized that this provision means that a defendant’s failure to timely file an answer constitutes acquiescence to the allegations in the complaint. Therefore, in such situations, the court’s role is to render judgment based on the facts alleged, not to weigh evidence as if an answer had been filed and issues joined. The court cited Don Tino Realty and Development Corporation v. Florentino, emphasizing that there is no provision for an entry of default under the Rules of Summary Procedure if the defendant fails to file an answer. Instead, the court renders judgment based on the complaint’s allegations.
The court also addressed the issue of whether Fairland was required to attach evidence, such as proof of ownership, to the complaint. The Court clarified that the rules do not mandate the attachment of evidence at the complaint stage, as the initial focus is on establishing a cause of action, and such evidence becomes relevant at a later stage of the summary procedure. The Court reiterated that inquiry into attached documents is for the sufficiency, not the veracity, of the material allegations in the complaint. Because Fairland’s complaint contained a valid cause of action for unlawful detainer, the Court found that a judgment could be rendered based on the complaint alone.
Furthermore, the Court noted that Po’s belated attempt to file a Comment/Opposition, which the MeTC treated as an answer but deemed filed out of time, merely denied the allegations without asserting any superior right of possession. The Supreme Court noted that, while unnecessary, Fairland attached a Condominium Certificate of Title to its Motion for Reconsideration, reinforcing its claim of ownership. The Court highlighted Sections 8 and 9 of the Rules on Summary Procedure, which specify that the presentation of affidavits and other evidence occurs after the preliminary conference, solidifying the principle that such evidence is not required at the initial complaint stage.
Finally, the Court clarified the relevance of the Judicial Affidavit Rule (A.M. No. 12-8-8-SC), which requires documentary or object evidence to be attached to a judicial affidavit. The Court stated that the rule was not applicable as it requires the attachments of documentary evidence to a judicial affidavit, not to a complaint, and it took effect after the filing of the case. Moreover, the Court explained that the attachments of documentary or object evidence to the affidavits is required when there would be a pre-trial or preliminary conference or the scheduled hearing. Where there is no answer, there is no need for a pre-trial, preliminary conference or hearing.
FAQs
| What was the key issue in this case? | The key issue was whether a court should base its judgment on the facts alleged in the complaint or require proof by preponderance of evidence when a defendant fails to file an answer in an unlawful detainer case under summary procedure. |
| What is unlawful detainer? | Unlawful detainer is a legal action to recover possession of real property from someone who initially had lawful possession but whose right to possession has expired or been terminated. This typically involves a landlord seeking to evict a tenant after the lease has ended or the tenant has violated its terms. |
| What happens if a defendant doesn’t file an answer in an unlawful detainer case? | Under the Rules on Summary Procedure, if a defendant fails to file an answer, the court is directed to render judgment based on the facts alleged in the complaint. This means the court does not require the plaintiff to present evidence to prove their case if the complaint states a valid cause of action. |
| Does the plaintiff still need to prove ownership of the property in an unlawful detainer case? | While ownership can be a factor, the primary issue in an unlawful detainer case is the right to physical possession. The plaintiff needs to establish a claim of right to possession that is superior to the defendant’s, which may involve proving ownership or a lease agreement. |
| What is the significance of the Rules on Summary Procedure? | The Rules on Summary Procedure are designed to expedite the resolution of certain cases, including unlawful detainer. These rules streamline the process and limit the timeframes for filing pleadings and presenting evidence to ensure a quick resolution. |
| Can a court dismiss an unlawful detainer case if no evidence is attached to the complaint? | The court can dismiss a case if the allegations in the complaint are insufficient to establish a cause of action, but it cannot dismiss the case solely because no evidence is attached. The attachment of evidence is not mandatory at the complaint stage. |
| What is the Judicial Affidavit Rule, and how does it relate to this case? | The Judicial Affidavit Rule requires parties to submit judicial affidavits of their witnesses, along with documentary evidence, before trial. However, the Supreme Court clarified that this rule does not apply when a defendant fails to file an answer, as there is no need for a trial or preliminary conference in such cases. |
| What was the outcome of this case? | The Supreme Court reversed the decisions of the lower courts and ordered Arturo Loo Po to vacate the condominium unit and pay the rentals in arrears. The Court found that Fairland’s complaint stated a valid cause of action for unlawful detainer and that Po’s failure to file an answer constituted an admission of the allegations in the complaint. |
This decision underscores the importance of responding to legal complaints promptly and the significance of a well-drafted complaint in unlawful detainer cases under summary procedure. It serves as a reminder that failure to answer a complaint can have significant consequences, as the court may render judgment based solely on the allegations presented by the plaintiff.
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: FAIRLAND KNITCRAFT CORPORATION VS. ARTURO LOO PO, G.R. No. 217694, January 27, 2016