Salaria v. Buenviaje
REITERATIONFacts
1. The Antecedents: Ramon Salaria had been a lessee on a residential lot owned by Eliodoro Cailao since 1930, paying a monthly rental that increased from P6.00 to P10.00. There was no fixed duration for the lease. In December 1972, Cailao instructed Salaria to stop paying rent and vacate the premises, as the land was to be sold to Antonio V. Mendiola. The land was subsequently sold to Mendiola and his wife in 1974. After December 1972, no further rent was collected, and Salaria deposited P200.00 with the Clerk of Court. Despite repeated requests to vacate, including a formal letter in May 1974, Salaria did not leave. 2. Procedural History: On August 23, 1974, Antonio V. Mendiola filed a complaint for unlawful detainer against Ramon Salaria in the City Court of Iriga. Salaria moved to dismiss, arguing that Presidential Decree No. 20 suspended the grounds for ejectment under Article 1673(1) of the Civil Code, and Mendiola's claimed need for the property was not an exception. The City Court denied the motion to dismiss and, after trial, ordered Salaria to vacate within three months, excused him from paying back rentals from January 1973 due to his financial situation, and directed the Clerk of Court to release the P200.00 deposit to Salaria. The City Court also dismissed Salaria's counterclaim. Upon appeal, the Court of First Instance of Camarines Sur affirmed the decision with modifications, ordering Salaria to vacate upon finality and allowing Mendiola to withdraw the deposited amount. 3. The Petition: This case reaches the Supreme Court via a petition for review on certiorari. Salaria argues that under Presidential Decree No. 20, Mendiola cannot eject him from the lot on the ground of personal use, as this is not a valid cause for ejectment under the suspended provisions of Article 1673(1) of the Civil Code. He contends that PD 20, read in conjunction with Article 1687 of the Civil Code, suspends the lessor's right to eject a lessee at the expiration of a lease period not fixed for a definite term. Salaria also cites Memorandum Circular No. 970 from the Office of the President, which clarifies that personal use is not a recognized cause for ejectment under PD 20, and emphasizes the protective intent of the decree for bona fide tenants.
Issue(s)
Whether Presidential Decree No. 20 allows the private respondent to eject the petitioner from the lot on the ground of personal use of the premises by the owner. Whether the case is covered by Presidential Decree No. 20.
Ruling
The decision of the Court of First Instance is reversed, except for the portion authorizing Antonio Mendiola to withdraw the P200.00 deposit. The petitioner is ordered to pay back rentals for the period not covered by the deposit at the rate of P10.00 per month. No costs.
Ratio Decidendi
On the applicability of Presidential Decree No. 20 and the ground for ejectment: The Court held that Presidential Decree No. 20, specifically Section 4, suspends the provisions of paragraph (1) of Article 1673 of the Civil Code, which pertains to ejectment upon the expiration of the lease period. The lease in question, having no fixed period and with monthly rentals, falls under Article 1687 of the Civil Code, which implies a lease from month to month. However, PD 20 explicitly suspends the ejectment ground based on the expiration of the period under Article 1673(1), even for leases governed by Article 1687. Furthermore, the ground of personal use of the premises by the owner or their family is not among the causes for judicial ejectment enumerated in Article 1673 of the Civil Code. The Court emphasized that allowing ejectment for personal use would circumvent the intent of PD 20 to protect lessees, particularly low-income families. The Memorandum Circular No. 970 issued by the Office of the President, clarifying PD 20, directly supported this interpretation, stating that personal use is not a recognized cause for ejectment. The Court gave weight to this executive interpretation, citing jurisprudence that the construction of the office charged with implementing a statute should be given controlling weight. Therefore, the petitioner could not be ordered to vacate based on the private respondent's need for personal use of the property. On the consignation of rentals: The Court noted that both the original and new owners refused to accept the rent offered by the petitioner. The petitioner's act of depositing the rentals with the Clerk of Court constituted consignation, which has the effect of payment and releases the lessee from the obligation to pay the lessor for the period covered by the deposit, pursuant to Article 1256 of the New Civil Code and jurisprudence. The Court affirmed the lower courts' decision to allow the private respondent to withdraw the P200.00 deposited, but clarified that the petitioner would still be liable for back rentals for the period not covered by this deposit, at the rate of P10.00 per month, as the consignation did not cover the entire period of arrears.
Main Doctrine
Presidential Decree No. 20 suspends the provision of paragraph (1) of Article 1673 of the Civil Code, which allows ejectment upon the expiration of the lease period, even if the lease is for an indefinite period and governed by Article 1687 of the Civil Code. The need of the lessor for the premises for personal use is not a ground for ejectment under PD 20.