Baens v.

Court of Appeals

Facts:

 Petitioner Baens (lessor) and private respondent Chua Seng (lessee) entered into an oral
contract of lease over the disputed property in Manila.
 Chua Seng left the premises and left paraphernalia of his store and other belongings.
 Chua Seng padlocked the door of the premises.
 Upon return Chua Seng learned that there were other padlocks mounted to the doors of
the premies as instructed by Baens, which the latter refused to remove despite demands.
 Chua Seng filed a case of Forcible Entry against Baens, for breach of contract and
deprivation of his right to occupy the premises.
 Baens in her answer denied Chua Seng’s right to occupy the property since the lease
agreement expired and Chua Seng failed to pay rent.
 Baens filed a separate case of Unlawful Detainer case against Chua Seng.
 The two cases were assigned to same MTC branch of City Court of Manila, which
conducted a joint trial
 The MTC rendered a consolidated decision in favor of Chua Seng and required Baens to
restore the former the possession leased premises and to pay him attorney’s fees
 Both parties appealed.
 Baens assailed the decision of the MTC, while Chua Seng assailed the part of the
decision of the MTC, which denied his claim for damages
 The CFI of Manila affirmed the MTC’s decision, and increased the award of damages to
be received by Chua Seng.
 Baens appealed the case to the CA.
 The CA, however, reversed the ruling of the CFI

Issue:
Whether the CA erred in lowering and not extinguishing the awarded moral and exemplary
damages to private respondent Chua Seng.

Ruling:
 Sec. 1 of Rule 70 of the Rules of Court provides:
o Subject to the provisions 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 landlord, 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 landlord, vendor,
vendee, or other person, may, at any time within one year after such unlawful
deprivation or withholding of possession, bring an action in the proper inferior
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.
 Damages may be awarded in forcible entry and detainer cases, in the form of reasonable
compensation for the use and occupation of the premises, or ‘fair rental value of the
property.
 Profits, which the plaintiff might have received were it not for the forcible entry or
detainer, do not represent a fair rental value.
 Although the provision does not use the word “damages”, the authors eliminated the
word “damages” and placed the phrase “reasonable compensation for the use and
occupation of the premises.”
 Since moral, exemplary, and actual damages are neither “rents” nor “reasonable
compensation for the use and occupation of the premises”, nor “fair rental value”, the
court is constrained to deny the grant of moral damages and exemplary damages awarded
by the respondent Court of Appeals including the award of actual damages awarded by
the MTC.