Gutierrez v. Cantada
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns an ejectment suit filed by Jose and Adelaida Gutierrez (petitioners) against Benjamin Leyva, with Armando and Carmelita Cantada (private respondents) intervening. The Cantadas had purchased a house built on the Gutierrezes' land, with the assurance that they could remain for a substantial number of years. The Cantadas admitted the Gutierrezes' ownership of the land and asserted their life savings were invested in the house. 2. Procedural History: The ejectment suit was initially filed with the City Court of Caloocan City on April 27, 1972. The respondent spouses filed an answer in intervention, admitting ownership but detailing their investment and assurances received. The City Court ruled in favor of the petitioners on September 21, 1972. The respondent spouses appealed to the Court of First Instance of Rizal, Caloocan City Branch XXXIII. On February 14, 1973, the respondent Judge reversed the City Court's decision, dismissing the ejectment complaint. 3. The Petition: The petitioners filed a petition for certiorari with the Supreme Court, seeking to reverse the decision of the respondent Judge. Their petition is primarily based on the argument that the respondent Judge erred in dismissing the ejectment suit. The Supreme Court, however, found that the respondent Judge correctly applied Republic Act No. 6359 and Presidential Decree No. 20, which suspended ejectment actions for leases not for a definite period, as a measure of police power to remedy the plight of lessees. The petitioners' attempt to raise a constitutional question regarding the equal protection clause of Republic Act No. 6359 was deemed raised too late and unavailing, especially in light of Presidential Decree No. 20.
Issue(s)
Whether the respondent Judge committed a grave abuse of discretion in dismissing the ejectment suit. Whether Republic Act No. 6359 and Presidential Decree No. 20, police power legislation suspending ejectment actions, are applicable to existing lease contracts. Whether Republic Act No. 6359 violates the equal protection clause.
Ruling
The petition for certiorari is dismissed. The decision of the respondent Judge dismissing the ejectment suit is affirmed.
Ratio Decidendi
On the applicability of police power legislation to existing contracts: The Court held that Republic Act No. 6359 and Presidential Decree No. 20 are police power legislation intended to remedy the plight of lessees. These laws, being remedial in character, are applicable to existing situations and contracts, otherwise, they would be self-defeating. The constitutional guaranty of non-impairment of contracts is limited by the exercise of the police power of the State in the interest of public health, safety, morals, and general welfare. The Court reiterated the doctrine established in Pangasinan Transportation Co. v. Public Service Commission and Ongsiako v. Gamboa, that police power measures cover existing situations. On the suspension of ejectment actions: The Court affirmed that Republic Act No. 6359 suspended ejectment actions for two years from its effectivity on July 14, 1971. The ejectment complaint in this case was filed on April 22, 1972, well within the suspension period. Furthermore, Presidential Decree No. 20 extended this suspension indefinitely until otherwise provided. The respondent Judge correctly applied these laws in dismissing the ejectment suit, as the lease was not for a definite period and the grounds for ejectment under Article 1673 of the Civil Code were not present or were suspended by the said decrees. On the alleged violation of the equal protection clause: The Court found the contention that Republic Act No. 6359 violates the equal protection clause to be unmeruasive. The Court stated that there was a clear need for such a statute to promote public interest and general welfare, as the State cannot stand idly by while a considerable segment of its citizens suffers from economic distress. The Court also noted the procedural objection that constitutional questions should be raised at the earliest opportunity, which was not done in this case.
Main Doctrine
Police power legislation, such as Presidential Decree No. 20 and Republic Act No. 6359, which suspends ejectment actions, is applicable to existing lease contracts and does not constitute an impairment of contractual obligations, as it is enacted in the interest of public health, safety, morals, and general welfare.