Dear Attorney,

I am writing to seek your advice on a matter that has caused significant concern. Recently, we received a final notice to vacate our rented apartment, identified with LRC Case No. 22-055, due to alleged non-payment of rent. However, the non-payment arose from a situation beyond our control: the new property owner has refused to issue a receipt acknowledging our payment, and there are multiple entities asserting their right to collect the rent.

As tenants, we are fully prepared to fulfill our rental obligations and have never intended to default on payments. However, given the conflicting claims over rightful collection, we sought to protect ourselves by requesting proof of payment, which has not been provided. In light of these circumstances, we are unsure if the owner can legally enforce this eviction or if there are legal remedies available to us to contest it.

Your expert guidance would be immensely helpful in navigating this matter. Thank you in advance for your assistance.

Sincerely,
A Concerned Tenant

Comprehensive Legal Analysis: Tenant’s Rights Amid Conflicting Rent Claims and Eviction Proceedings

Evictions and rental disputes are governed by various laws in the Philippines, including the Civil Code, Presidential Decree No. 20, and the Rent Control Act (RA 9653, as amended). When a tenant faces eviction due to non-payment, particularly in a situation involving conflicting claims over the right to collect rent, understanding these laws becomes critical.

1. Grounds for Eviction under Philippine Law

Eviction from a rented property must comply with specific legal grounds. Under the Rent Control Act and jurisprudence, the following are valid reasons for eviction:

Non-payment of rent for at least three consecutive months, subject to proper notice.
Unauthorized subleasing of the property.
Necessity of the landlord to use the property for personal or family residence, provided the tenant has been duly notified six months in advance.
Major property repairs or demolition.
Expiration of the lease contract and refusal of the tenant to vacate despite notice.

In your case, the landlord has cited non-payment of rent as the ground for eviction. However, the non-payment appears to be a consequence of conflicting claims on who is entitled to collect rent, which significantly complicates the situation.

2. Conflicting Claims Over Rent Collection

When multiple parties assert their right to collect rent, tenants are put in a precarious position. This often arises in cases of property disputes or ownership transitions. The Civil Code of the Philippines offers guidance:

Article 1242 states that payment should be made to the party who is legally entitled to receive it.
If the entitlement of the collector is in doubt, Article 1256 allows the debtor (in this case, the tenant) to protect themselves by:
- Depositing the rent payment in court through consignation.

This legal process effectively transfers the obligation from the debtor to the court, ensuring compliance while resolving uncertainties about entitlement. As such, tenants like you should not be penalized for non-payment when you have acted in good faith by seeking to ascertain the rightful payee.

3. Refusal to Issue Receipts

Under the Civil Code, landlords are legally required to issue receipts for rent payments:

Article 1233 stipulates that proof of payment is necessary to extinguish an obligation.
Article 1358(1) mandates that certain acts, including receipts for payments, must be in writing to serve as evidence.

A refusal to issue receipts violates the law and undermines the landlord’s claim for rent collection. In such cases, the tenant’s demand for proof of payment is not only reasonable but also legally justified.

4. Procedures for Contesting Eviction

If eviction proceedings have been initiated against you, the following steps can be taken:

A. Verify the Validity of the Notice to Vacate

A notice to vacate must comply with legal requirements, including a written demand for rent payment and a reasonable period to comply (typically 15 days for residential properties).
Failure to issue a valid notice invalidates the eviction proceedings.

B. File a Complaint with the Housing and Land Use Regulatory Board (HLURB)

Disputes involving tenant rights under the Rent Control Act can be brought before the HLURB, now part of the Department of Human Settlements and Urban Development (DHSUD).

C. Seek Judicial Relief

File a petition to enjoin the eviction in the appropriate court if the landlord is acting in bad faith or violating the terms of the lease.
A court may issue a temporary restraining order (TRO) or injunction to prevent unlawful eviction.

5. Depositing Rent Through Consignation

To avoid allegations of non-payment, tenants should consider consignation under Article 1256 of the Civil Code:

Steps in Consignation:

Notify the landlord or claimants of your intent to consign the rent payment.
Deposit the rent with the proper court or a government agency (if applicable) after due notice.
Submit evidence of your attempt to pay and the conflicting claims to the court.

By consigning the rent, you demonstrate good faith and protect yourself from eviction on the grounds of non-payment.

6. Remedies for Tenants

A. Protection Against Forcible Eviction

Eviction without a court order constitutes illegal eviction under Philippine law. Tenants cannot be forcibly removed from the premises without due process.
File a case for illegal eviction if the landlord uses threats, harassment, or force to evict you.

B. Legal Recourse for Damages

If you suffer undue stress or losses due to the landlord’s actions, you may file for damages under Article 19 and Article 21 of the Civil Code for abuse of rights and acts contrary to morals, good customs, or public policy.

C. Mediation and Arbitration

Seek mediation through the Barangay Justice System or the DHSUD to resolve disputes amicably.

7. Practical Advice for Tenants

Document Everything: Keep records of all communications, notices, and attempts to pay rent.
Secure Legal Representation: A lawyer can help you navigate the complexities of eviction laws and protect your rights.
Pay Under Protest: If the rightful payee is identified later, ensure compliance to avoid further legal complications.

Conclusion

The landlord cannot lawfully evict you if the non-payment was caused by conflicting claims over the rent or their refusal to issue receipts. Philippine law provides tenants with robust protections, including the right to due process, consignation, and recourse against illegal eviction.

By acting in good faith and utilizing the remedies available under the law, you can safeguard your rights while fulfilling your obligations as a tenant. It is highly recommended to consult a lawyer to assist in implementing these measures effectively.