Fairland Knitcraft Corporation vs. Arturo Loo Po

In an ejectment case governed by the Rules of Summary Procedure, if the defendant fails to file an answer, the court must render judgment based solely on the facts alleged in the complaint and limited to what is prayed for, without requiring the plaintiff to present evidence or prove its claims by preponderance of evidence.

Fairland Knitcraft Corporation leased Condominium Unit No. 205 in Cedar Mansion II, Pasig City, to Arturo Loo Po under a verbal month-to-month agreement for P20,000.00 monthly. Po stopped paying rent in March 2011, prompting Fairland to demand payment and vacation of the premises. When Po refused, Fairland filed an unlawful detainer case.

Fairland Knitcraft Corporation owned Condominium Unit No. 205 in Cedar Mansion II, Pasig City, which it leased to Arturo Loo Po under a verbal agreement at P20,000.00 per month. Po failed to pay rent from March 2011, leading Fairland to decide against renewing the lease. On January 30, 2012, Fairland sent a demand letter requiring Po to pay P220,000.00 in arrears and vacate within fifteen days. Po ignored the demand, prompting Fairland to file an unlawful detainer complaint before the MeTC on December 12, 2012.

Summons was served on Po on December 28, 2012, giving him until January 7, 2013 to file an answer. Po failed to do so, and Fairland moved to render judgment. On March 1, 2013, Po's counsel belatedly filed an entry of appearance with a comment/opposition, denying the allegations and arguing lack of proof of ownership, absence of a lease contract, and that the RTC had jurisdiction due to an ownership issue. The MeTC treated this as an answer but deemed it filed out of time under the Rules of Summary Procedure.

The MeTC dismissed the complaint for lack of merit, finding that Fairland failed to prove its entitlement to possession by preponderance of evidence. Fairland appealed to the RTC, which affirmed the dismissal, noting that even if Po was not the owner, his actual physical possession created a presumption of entitlement. Fairland then elevated the case to the CA, which similarly ruled that the action would not lie because Fairland failed to prove ownership and the identity of the property. The CA emphasized that summary procedure did not relax the rules on evidence. Fairland subsequently filed a motion for reconsideration, attaching its condominium certificate of title, but it was denied, leading to the present petition.

• Judgment Based on Complaint: Petitioner argued that under the Rules of Summary Procedure, when a defendant fails to file an answer, the court must render judgment based solely on the facts alleged in the complaint, without requiring preponderance of evidence.
• Attachment of Evidence Not Required: Petitioner maintained that documentary evidence need not be attached to the complaint, as the presentation of evidence is dispensed with when no answer is filed, and the inquiry is limited to the sufficiency of the cause of action.

• Question of Fact: Respondent countered that the petition raised a question of fact, identical to the issues before the CA.
• Necessity of Evidence: Respondent argued that there was no legal basis to dispense with evidence when no answer was filed, as doing so would undermine the court's authority to resolve issues based on facts and rules of evidence. The court decided based on the complaint, which was found wanting in preponderance of evidence.

• Judgment in Ejectment Without Answer: Whether the MeTC erred in dismissing the unlawful detainer case for lack of preponderance of evidence instead of rendering judgment based on the facts alleged in the complaint due to the defendant's failure to file an answer.
• Attachment of Evidence to Complaint: Whether the plaintiff in an ejectment case is required to attach documentary evidence to the complaint to prove its cause of action.

• Judgment in Ejectment Without Answer: Yes. The lower courts erred in requiring preponderance of evidence; under Section 6 of the Rules of Summary Procedure, judgment must be rendered based solely on the facts alleged in the complaint when the defendant fails to answer.
• Attachment of Evidence to Complaint: No. The rules do not compel the plaintiff to attach evidence to the complaint; the failure to file an answer constitutes acquiescence to the allegations, rendering such attachments unnecessary if the complaint states a sufficient cause of action.

• Judgment in Ejectment Without Answer: Section 6 of the Rules on Summary Procedure and Section 7 of Rule 70 of the Rules of Court explicitly state that if the defendant fails to answer, the court shall render judgment as warranted by the facts alleged in the complaint and limited to the prayer. The failure to timely file an answer constitutes acquiescence to every allegation in the complaint. Thus, the MeTC should have rendered judgment based on the complaint, which sufficiently alleged a cause of action for unlawful detainer, instead of dismissing it for lack of evidence.
• Attachment of Evidence to Complaint: In an unlawful detainer case, only de facto possession is required, making the attachment of a deed of ownership unnecessary. Since Fairland sufficiently alleged ownership and superior right of possession, and Po failed to answer (deemed admitting these allegations), supporting attachments were not needed. Evidence is only required at the later stage of summary procedure (submission of affidavits and position papers), which is mooted by the defendant's failure to answer. The Judicial Affidavit Rule also does not apply because it requires attachments for pre-trial or hearings, which are unnecessary when no answer is filed.

• Judgment Based on the Complaint under Summary Procedure — Under Section 6 of the Rules of Summary Procedure and Section 7 of Rule 70 of the Rules of Court, if the defendant fails to file an answer within the prescribed period, the court, motu proprio or on motion of the plaintiff, shall render judgment based solely on the facts alleged in the complaint and limited to what is prayed for. The failure to answer constitutes acquiescence to all material allegations, dispensing with the need for the plaintiff to present evidence.
• Elements of Unlawful Detainer — A complaint sufficiently alleges a cause of action for unlawful detainer if it recites: (1) initially, possession of the property by the defendant was by contract with or by tolerance of the plaintiff; (2) eventually, such possession became illegal upon notice by the plaintiff to the defendant of the termination of the latter's right of possession; (3) thereafter, the defendant remained in possession and deprived the plaintiff of enjoyment thereof; and (4) within one year from the last demand to vacate, the plaintiff instituted the complaint.

• "The failure of the defendant to timely file his answer and to controvert the claim against him constitutes his acquiescence to every allegation stated in the complaint. Logically, there is nothing to be done in this situation except to render judgment as may be warranted by the facts alleged in the complaint." — This passage articulates the ratio decidendi for dispensing with the need for preponderance of evidence when a defendant fails to answer in a summary proceeding.
• "The lower courts erroneously dismissed the complaint of Fairland simply on the ground that it failed to establish by preponderance of evidence its ownership over the subject property. As can be gleaned above, the rules do not compel the plaintiff to attach his evidence to the complaint because, at this inception stage, he only has to file his complaint to establish his cause of action." — This clarifies that evidentiary requirements are relaxed at the inception stage of a summary proceeding if the complaint states a sufficient cause of action.

• Don Tino Realty and Development Corporation vs. Florentino, 372 Phil. 882 (1999) — Cited to support the rule that there is no provision for an entry of default under the Rules of Summary Procedure if the defendant fails to file an answer, and that ejectment cases are summary proceedings designed for expeditious determination.
• Lazaro vs. Brewmaster, 642 Phil. 710 (2010) — Cited to emphasize that inquiry into attached documents is for the sufficiency, not the veracity, of the material allegations in the complaint, and that attachments are unnecessary if the complaint already alleges a sufficient cause of action.
• Zacarias vs. Anacay, G.R. No. 202354, September 24, 2014 — Cited for the enumeration of the elements required to sufficiently allege a cause of action for unlawful detainer.

• Section 1, Rule 70, Rules of Court — Defines unlawful detainer and lays down the requirements for filing a complaint, establishing that the action is for recovery of possession after the expiration or termination of the right to hold possession.
• Sections 5 and 6, Rules on Summary Procedure — Prescribe the period to file an answer and mandate that upon failure to answer, the court shall render judgment based solely on the facts alleged in the complaint and limited to what is prayed for.
• Section 7, Rule 70, Rules of Court — Governs forcible entry and unlawful detainer, stating that if the defendant fails to answer, the court shall render judgment as warranted by the facts alleged in the complaint without declaring the defendant in default.
• Sections 8 and 9, Rules on Summary Procedure (Sections 9 and 10, Rule 70, Rules of Court) — Provide for the submission of affidavits and position papers at the later stage of the preliminary conference, indicating when evidence is actually required.
• Section 2, Judicial Affidavit Rule (A.M. No. 12-8-8-SC) — Requires the submission of judicial affidavits and exhibits before pre-trial or preliminary conference, which is inapplicable when no answer is filed and judgment is rendered based on the complaint.

Antonio T. Carpio (Chairperson), Arturo D. Brion, Mariano C. Del Castillo, Marvic M.V.F. Leonen.