TL;DR

In ejectment cases under summary procedure, if a defendant fails to file an answer, the court must render judgment based solely on the facts alleged in the plaintiff’s complaint. This means the plaintiff wins by default if their complaint sufficiently states a cause of action, without needing to present further evidence. This ruling underscores the importance of responding to court summons promptly, as failure to answer can be construed as an admission of the plaintiff’s claims, leading to an automatic victory for the plaintiff.

Unheard Defense, Undisputed Claim: The Case of the Silent Tenant

This case, Fairland Knitcraft Corporation v. Arturo Loo Po, revolves around a fundamental principle in Philippine remedial law: the effect of silence in summary procedure cases, particularly in ejectment suits. At its core, the Supreme Court clarified that in unlawful detainer cases governed by summary procedure, a defendant’s failure to answer the complaint within the prescribed period has significant consequences. It isn’t about proving guilt beyond a reasonable doubt, or even by preponderance of evidence, when the defendant chooses not to contest the allegations. The central question becomes: what happens when a tenant, accused of non-payment and refusal to vacate, simply does not respond to the court’s summons?

Fairland Knitcraft Corporation, claiming ownership of a condominium unit, initiated an unlawful detainer action against Arturo Loo Po, alleging a verbal lease agreement, non-payment of rent, and a subsequent demand to vacate. Po, despite being served summons, did not file an answer within the reglementary period. The Metropolitan Trial Court (MeTC), Regional Trial Court (RTC), and Court of Appeals (CA) all ruled against Fairland, citing a failure to prove its case by preponderance of evidence. These lower courts insisted on evidence of ownership and the lease agreement, even in the absence of a defense from Po. This approach, the Supreme Court declared, was erroneous and misapplied the Rules of Summary Procedure.

The Supreme Court meticulously dissected the relevant provisions of the Rules of Summary Procedure and Rule 70 of the Rules of Court, which governs ejectment cases. Section 6 of the Rules on Summary Procedure explicitly states that if a defendant fails to answer, the court “shall render judgment as may be warranted by the facts alleged in the complaint.” This provision, the Court emphasized, does not mandate an evaluation of evidence in the traditional sense when no answer is filed. Instead, it directs the court to assess the sufficiency of the complaint itself. Did Fairland’s complaint, on its face, articulate a valid cause of action for unlawful detainer? The Supreme Court found that it did. The complaint clearly alleged Fairland’s ownership, a verbal lease agreement with Po, Po’s failure to pay rent, a demand to vacate, and the filing of the case within one year from the last demand – all essential elements of unlawful detainer.

The Court highlighted that the purpose of summary procedure is to expedite the resolution of cases like ejectment. Requiring plaintiffs to present extensive evidence, even when the defendant defaults, defeats this purpose. The failure to answer, in this context, is not a mere procedural lapse; it is an implicit admission of the facts alleged in the complaint. To demand preponderance of evidence in such a scenario is to ignore the explicit language and intent of the Rules. The Supreme Court quoted its previous rulings, underscoring that there is no provision for a declaration of default in summary procedure; instead, the remedy for failure to answer is judgment based on the complaint. This is a crucial distinction, setting summary procedure apart from ordinary civil actions.

Furthermore, the Supreme Court addressed the lower courts’ insistence on documentary evidence of ownership attached to the complaint. The Court clarified that while attachments can be considered to determine the sufficiency of the complaint, they are not mandatory at this stage. The focus is on whether the allegations in the complaint, if taken as true, establish a cause of action. In unlawful detainer cases, the core issue is possession, not ownership. While ownership may be provisionally considered, it is not the primary determinant in a summary ejectment proceeding. Fairland’s allegation of ownership and the lease agreement, coupled with Po’s silence, were deemed sufficient to warrant judgment in Fairland’s favor.

In reversing the Court of Appeals, the Supreme Court underscored the practical implications of its ruling. It reinforces the importance of timely and proper responses to court summons, especially in summary procedure cases. Defendants cannot simply ignore complaints and expect the plaintiff to overcome evidentiary hurdles as if a full-blown trial were underway. The Rules of Summary Procedure are designed for efficiency and prompt resolution. A defendant’s silence, in the face of a sufficiently pleaded complaint, speaks volumes and can be legally interpreted as acquiescence, leading to judgment based on the unchallenged allegations.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.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 v. Arturo Loo Po, G.R. No. 217694, January 27, 2016