Unlawful Detainer: Why a Sufficient Complaint Wins Even When Defendant Defaults

The Supreme Court's 2016 ruling in Fairland Knitcraft Corporation v. Arturo Loo Po (G.R. No. 217694) clarifies a critical point in ejectment cases: when a defendant fails to file an answer under the Rules on Summary Procedure, the court must render judgment based solely on the facts alleged in the complaint—not on a preponderance of evidence. This decision protects plaintiffs who have properly stated a cause of action but were dismissed for failing to present evidence they were never required to submit at that stage.

The Facts of the Case

Fairland Knitcraft Corporation owned a condominium unit in Pasig City that it leased to Arturo Loo Po under a verbal, month-to-month agreement at ₱20,000 per month. Beginning March 2011, Po stopped paying rent. Fairland sent a formal demand letter on January 30, 2012, requiring Po to pay ₱220,000 in arrears and vacate within fifteen days. Po did neither.

Fairland filed an unlawful detainer complaint on December 12, 2012. Po received summons but failed to file his answer by the January 7, 2013 deadline. Fairland moved for judgment, and the Metropolitan Trial Court (MeTC) considered the case submitted for decision.

Po's counsel then filed a belated Entry of Appearance with a motion to file a comment opposing the motion for judgment. The MeTC treated this as an answer but deemed it filed out of time and denied the motion.

The Procedural Error

Despite acknowledging that the complaint stated a valid cause of action, the MeTC dismissed the case for lack of preponderance of evidence, noting that Fairland presented no proof of ownership or lease. The Regional Trial Court and Court of Appeals affirmed.

The Supreme Court reversed, finding the lower courts erred. Under Section 6 of the Rules on Summary Procedure, when a defendant fails to answer, "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 same principle appears in Section 7, Rule 70 of the Rules of Court governing ejectment cases.

The Court's Reasoning

The Court explained that a defendant's failure to file a timely answer constitutes acquiescence to every allegation in the complaint. There is no need for evidence because the defendant has effectively admitted the plaintiff's claims.

The Court also rejected the lower courts' insistence on documentary attachments. Under Section 4 of the Rules of Summary Procedure, attaching evidence to the complaint is not mandatory. Citing Lazaro v. Brewmaster (642 Phil. 710), the Court emphasized that the inquiry at this stage concerns the sufficiency, not the veracity, of the complaint's allegations.

In unlawful detainer, only de facto or material possession must be alleged—not full ownership. Fairland's complaint sufficiently alleged ownership, an oral lease, non-payment of rent, a demand to vacate, and the defendant's refusal. These elements established a valid cause of action.

The Remedy

Finding no need to remand, the Court rendered judgment itself, ordering Po to vacate the unit and pay rental arrears plus accruing rentals, with six percent interest per annum from the date of demand.

Practical Takeaways

• A sufficient complaint is enough when the defendant defaults. In summary procedure cases, failure to answer means judgment is based on the complaint's allegations alone.
• Evidence need not be attached to the complaint. The Rules on Summary Procedure do not require annexes; the complaint need only state a cause of action.
• Distinguish sufficiency from veracity. Courts examine whether the complaint alleges enough facts—not whether those facts are true—when no answer is filed.
• Act promptly on demand. Unlawful detainer complaints must be filed within one year from the last demand to vacate.
• A belated answer is no answer. Filing out of time does not cure the default or require the court to consider the defendant's defenses.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.