Reyes v. Arca
REITERATIONFacts
The Antecedents: Spouses Feliciano and Pilar Basa leased three parcels of land with improvements to Eusebio Millar for five years, renewable for another five years. The lease agreement included an option for the lessee to buy the property should the lessors decide to sell, stipulating that if sold to a third party, the terms of the lease agreement shall be respected by the buyer. Procedural History: The properties were sold to Jose Reyes, Soledad Reyes, and Carmelita Reyes de Pastor, who respected the lease. Eusebio Millar filed an action to nullify the sale, exercise his option to purchase, and claim damages. He deposited monthly rentals with the court to avoid complications. The trial court allowed Millar to withdraw the accumulated deposits upon filing a surety bond. Later, the purchasers moved for Millar to deposit subsequent rentals, which the trial court denied. The Petition: The purchasers, Jose Reyes, Soledad Reyes, and Carmelita Reyes de Pastor, filed a petition for certiorari and mandamus with the Supreme Court to set aside the denial orders and compel Eusebio Millar to deposit the unpaid rentals. They sought to have the trial court's orders of March 20, 1963, and April 6, 1963, set aside, and to compel Millar to deposit P16,640.00 for rentals from January 1959 to April 1963, and P320.00 monthly thereafter.
Issue(s)
Whether the trial court committed grave abuse of discretion in denying the motion to require the lessee to deposit unpaid rentals. Whether certiorari is the proper remedy to set aside the trial court's orders.
Ruling
The petition for certiorari is granted. The orders dated March 20, 1963, and April 6, 1963, are set aside. Respondent Eusebio Millar is ordered to deposit with the trial court the sum of P16,640.00 for rentals from January 1959 to April 1963, and monthly rentals of P320.00 for every month thereafter.
Ratio Decidendi
On Issue 1: The Supreme Court held that the trial court committed grave abuse of discretion tantamount to excess of jurisdiction in allowing the suspension of rent payment by respondent Eusebio Millar. As a lessee, Millar has the specific duty under Article 1657 of the New Civil Code to pay the rent according to the terms stipulated. Article 1658 provides the only instances where a lessee may suspend payment of rent, namely, when the lessor fails to make necessary repairs or to maintain the lessee in peaceful and adequate enjoyment of the property. None of these grounds were present in the case. By allowing the suspension of rentals without legal basis, the trial court sanctioned the unjust enjoyment of another's property without payment, which runs counter to the cardinal rule on human relations that every person must act with justice, give everyone his due, and observe honesty and good faith, as stated in Article 19 of the New Civil Code. On Issue 2: The Supreme Court ruled that certiorari is an available and proper remedy in this case. The Court found that an appeal from the trial court's orders would not be a speedy and adequate remedy because such an appeal could only be taken after the case was decided on the merits, and the trial was far from finished. Given the trial court's grave abuse of discretion in issuing the questioned orders, the remedy of certiorari under Section 1 of Rule 65 of the Revised Rules of Court was available to set aside these orders.
Main Doctrine
The Supreme Court reiterated that a lessee's fundamental obligation is to pay rent as stipulated in the lease agreement and as mandated by Article 1657 of the New Civil Code. Article 1658 provides the exclusive grounds for a lessee to suspend rent payment, which are the lessor's failure to make necessary repairs or to maintain the lessee in peaceful and adequate enjoyment of the property. When a trial court allows the suspension of rent payment without any legal basis, it acts with grave abuse of discretion amounting to excess of jurisdiction, and the remedy of certiorari under Rule 65 of the Rules of Court is available to set aside such erroneous orders, especially when appeal would not be a speedy and adequate remedy.